Coffee <martin.coffee@round-midnight.org.uk> wrote:
> On 06/12/2023 10:27, Tweed wrote:
>> Roland Perry <roland@perry.uk> wrote:
>>> In message <kt9c10F931dU1@mid.individual.net>, at 19:29:35 on Tue, 5 Dec
>>> 2023, Rupert Moss-Eccardt <nin@moss-eccardt.com> remarked:
>>>> On 3 Dec 2023 10:23, Roland Perry wrote:
>>>>> In message <ukhdge$2phim$1@dont-email.me>, at 08:16:14 on Sun, 3 Dec
>>>>> 2023, Tweed <usenet.tweed@gmail.com> remarked:
>>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>>> In message <3gsjmihrn2o0vvos598s3pt3p069e8c08c@4ax.com>, at 14:56:10 on
>>>>>>> Fri, 1 Dec 2023, Recliner <recliner.usenet@gmail.com> remarked:
>>>>>>>> On Fri, 1 Dec 2023 14:45:15 +0000, GB
>>>>>>>> <NOTsomeone@microsoft.invalid> wrote:
>>>>>>>>
>>>>>>>>> On 01/12/2023 09:42, Roland Perry wrote:
>>>>>>>>>
>>>>>>>>>> Even if I had such a vote, I would not cast it to implement quite such a
>>>>>>>>>> broken IT system.
>>>>>>>>>
>>>>>>>>> I think that everybody here agrees with you that the IT system is broken.
>>>>>>>>>
>>>>>>>>> Apart from the annoyance to people like yourself, it must cause much
>>>>>>>>> work within TFL sorting out the mess. And, there's no obvious reason for
>>>>>>>>> the slow updates of the fine system.
>>>>>>>>
>>>>>>>> One word explanation: Crapita
>>>>>>>>
>>>>>>>> https://www.capita.com/news/capita-operated-ultra-low-emission-zone-
>>>>>>>> expansion-launches-london
>>>>>>>>
>>>>>>>>> Nevertheless, you are going on a bit.
>>>>>>>>
>>>>>>>> Indeed so, but it's all new and shocking for Roland.
>>>>>>>>
>>>>>>>> This has actually been going on for years, and has been widely reported
>>>>>>>> in the media and in local groups:
>>>>>>>> https://www.reddit.com/r/london/comments/owj4ll/psa_your_private_plate_
>>>>>>>> can_make_you_car_seem_ulez/
>>>>>>>
>>>>>>> "they explained that DVLA doesn't give complete information when
>>>>>>> it's a private plate so they just make the car non-compliant"
>>>>>>>
>>>>>>> That's nonsense because TfL got the correct vehicle make and number from
>>>>>>> DVLA, which means they could also get the date of first registration,
>>>>>>> which confirms automatic compliance (only by six months, but one day
>>>>>>> would be sufficient).
>>>>>>>
>>>>>>> If it's been going on for years, then they've had plenty of time to fix
>>>>>>> it.
>>>>>>>
>>>>>>> I note a recent FOI response from TfL confirming they only update the
>>>>>>> database they check ANPR against "once a month", but failed to say when
>>>>>>> in the month, or answer the second part of the enquiry which was about
>>>>>>> its wider impact on personal plate holders.
>>>>>>>
>>>>>>> As it happens, my vehicle was issued with a V5 a month and a day before
>>>>>>> the alleged offence, and their database wasn't so out of date it had the
>>>>>>> wrong vehicle description. So this is a different type of glitch. If it
>>>>>>> had still said "Freelander" I'd be going about this quite differently.
>>>>>>>
>>>>>>> And part of the issue I have is the asymmetry - they say fines must be
>>>>>>> paid within 14 days (and in my case the notice spent the first 5 days in
>>>>>>> the post), but they give themselves a whole month to issue invalid
>>>>>>> notices.
>>>>>>>
>>>>>>> They also have an absolute deadline of responding to the notice by Xmas
>>>>>>> Eve, and although I accept it can be done online, the default is by
>>>>>>> post, and it's unclear if a proof-of-posting is evidence of "serving"
>>>>>>> the appeal, rather than the date they open the letter (which in any
>>>>>>> event they are stunningly unlikely to do on Xmas Eve, Xmas Day, or
>>>>>>> Boxing Day).
>>>>>>
>>>>>> Any entanglement with authorities that have some form of legislative
>>>>>> backing to their position is always asymmetric and not in favour of
>>>> the
>>>>>> individual. Just be thankful that you've not been accused of a serious
>>>>>> criminal offence that you didn't commit.
>>>>>
>>>>> Actually, TfL is committing a criminal offence because they are holding
>>>>> (and processing) needlessly inaccurate data, and that's a contravention
>>>>> of GDPR.
>>>>
>>>> I'm not sure VRMs identify individuals beyond the keeper and the
>>>> personal data in your case isn't wrong. Just some associated data.
>>>
>>> "just associated data" is the whole point.
>>>
>>> In the case of ULEZ PNs, it clearly has the keeper's name and address
>>> on, for example, which in the case in question is *correct* (as is the
>>> make and model of the vehicle), what's in error is the data they are
>>> holding which says that the keeper is driving a non-compliant vehicle,
>>> which is clearly not the case.
>>>
>> As I understand it, GDPR requires personal data to be accurate (in general
>> terms with exceptions). I don’t see that the incorrect ULEZ classification
>> of a vehicle is personal data. The name and address of where to send the
>> penalty is, but that’s different.
>
> Data processing also has to be fair and correct so this PN does not
> comply with GDPR.
>
>

Do you have a cite for that last assertion? In its logical absurdity, I can
have data about moon orbits that I can process with an incorrect equation.
That produces incorrect data. That isn’t an offence under GDPR.

On 08/12/2023 19:28, Tweed wrote:
> Coffee <martin.coffee@round-midnight.org.uk> wrote:
>> On 06/12/2023 10:27, Tweed wrote:
>>> Roland Perry <roland@perry.uk> wrote:
>>>> In message <kt9c10F931dU1@mid.individual.net>, at 19:29:35 on Tue, 5 Dec
>>>> 2023, Rupert Moss-Eccardt <nin@moss-eccardt.com> remarked:
>>>>> On 3 Dec 2023 10:23, Roland Perry wrote:
>>>>>> In message <ukhdge$2phim$1@dont-email.me>, at 08:16:14 on Sun, 3 Dec
>>>>>> 2023, Tweed <usenet.tweed@gmail.com> remarked:
>>>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>>>> In message <3gsjmihrn2o0vvos598s3pt3p069e8c08c@4ax.com>, at 14:56:10 on
>>>>>>>> Fri, 1 Dec 2023, Recliner <recliner.usenet@gmail.com> remarked:
>>>>>>>>> On Fri, 1 Dec 2023 14:45:15 +0000, GB
>>>>>>>>> <NOTsomeone@microsoft.invalid> wrote:
>>>>>>>>>
>>>>>>>>>> On 01/12/2023 09:42, Roland Perry wrote:
>>>>>>>>>>
>>>>>>>>>>> Even if I had such a vote, I would not cast it to implement quite such a
>>>>>>>>>>> broken IT system.
>>>>>>>>>>
>>>>>>>>>> I think that everybody here agrees with you that the IT system is broken.
>>>>>>>>>>
>>>>>>>>>> Apart from the annoyance to people like yourself, it must cause much
>>>>>>>>>> work within TFL sorting out the mess. And, there's no obvious reason for
>>>>>>>>>> the slow updates of the fine system.
>>>>>>>>>
>>>>>>>>> One word explanation: Crapita
>>>>>>>>>
>>>>>>>>> https://www.capita.com/news/capita-operated-ultra-low-emission-zone-
>>>>>>>>> expansion-launches-london
>>>>>>>>>
>>>>>>>>>> Nevertheless, you are going on a bit.
>>>>>>>>>
>>>>>>>>> Indeed so, but it's all new and shocking for Roland.
>>>>>>>>>
>>>>>>>>> This has actually been going on for years, and has been widely reported
>>>>>>>>> in the media and in local groups:
>>>>>>>>> https://www.reddit.com/r/london/comments/owj4ll/psa_your_private_plate_
>>>>>>>>> can_make_you_car_seem_ulez/
>>>>>>>>
>>>>>>>> "they explained that DVLA doesn't give complete information when
>>>>>>>> it's a private plate so they just make the car non-compliant"
>>>>>>>>
>>>>>>>> That's nonsense because TfL got the correct vehicle make and number from
>>>>>>>> DVLA, which means they could also get the date of first registration,
>>>>>>>> which confirms automatic compliance (only by six months, but one day
>>>>>>>> would be sufficient).
>>>>>>>>
>>>>>>>> If it's been going on for years, then they've had plenty of time to fix
>>>>>>>> it.
>>>>>>>>
>>>>>>>> I note a recent FOI response from TfL confirming they only update the
>>>>>>>> database they check ANPR against "once a month", but failed to say when
>>>>>>>> in the month, or answer the second part of the enquiry which was about
>>>>>>>> its wider impact on personal plate holders.
>>>>>>>>
>>>>>>>> As it happens, my vehicle was issued with a V5 a month and a day before
>>>>>>>> the alleged offence, and their database wasn't so out of date it had the
>>>>>>>> wrong vehicle description. So this is a different type of glitch. If it
>>>>>>>> had still said "Freelander" I'd be going about this quite differently.
>>>>>>>>
>>>>>>>> And part of the issue I have is the asymmetry - they say fines must be
>>>>>>>> paid within 14 days (and in my case the notice spent the first 5 days in
>>>>>>>> the post), but they give themselves a whole month to issue invalid
>>>>>>>> notices.
>>>>>>>>
>>>>>>>> They also have an absolute deadline of responding to the notice by Xmas
>>>>>>>> Eve, and although I accept it can be done online, the default is by
>>>>>>>> post, and it's unclear if a proof-of-posting is evidence of "serving"
>>>>>>>> the appeal, rather than the date they open the letter (which in any
>>>>>>>> event they are stunningly unlikely to do on Xmas Eve, Xmas Day, or
>>>>>>>> Boxing Day).
>>>>>>>
>>>>>>> Any entanglement with authorities that have some form of legislative
>>>>>>> backing to their position is always asymmetric and not in favour of
>>>>> the
>>>>>>> individual. Just be thankful that you've not been accused of a serious
>>>>>>> criminal offence that you didn't commit.
>>>>>>
>>>>>> Actually, TfL is committing a criminal offence because they are holding
>>>>>> (and processing) needlessly inaccurate data, and that's a contravention
>>>>>> of GDPR.
>>>>>
>>>>> I'm not sure VRMs identify individuals beyond the keeper and the
>>>>> personal data in your case isn't wrong. Just some associated data.
>>>>
>>>> "just associated data" is the whole point.
>>>>
>>>> In the case of ULEZ PNs, it clearly has the keeper's name and address
>>>> on, for example, which in the case in question is *correct* (as is the
>>>> make and model of the vehicle), what's in error is the data they are
>>>> holding which says that the keeper is driving a non-compliant vehicle,
>>>> which is clearly not the case.
>>>>
>>> As I understand it, GDPR requires personal data to be accurate (in general
>>> terms with exceptions). I don’t see that the incorrect ULEZ classification
>>> of a vehicle is personal data. The name and address of where to send the
>>> penalty is, but that’s different.
>>
>> Data processing also has to be fair and correct so this PN does not
>> comply with GDPR.
>>
>>
>
> Do you have a cite for that last assertion? In its logical absurdity, I can
> have data about moon orbits that I can process with an incorrect equation.
> That produces incorrect data. That isn’t an offence under GDPR.
>
Moon orbits are not a person. Roland is.

On 9 Dec 2023 08:59, Coffee wrote:
> On 08/12/2023 19:28, Tweed wrote:
>> Coffee <martin.coffee@round-midnight.org.uk> wrote:
>>> On 06/12/2023 10:27, Tweed wrote:
>>>> Roland Perry <roland@perry.uk> wrote:
>>>>> In message <kt9c10F931dU1@mid.individual.net>, at 19:29:35 on Tue, 5 Dec
>>>>> 2023, Rupert Moss-Eccardt <nin@moss-eccardt.com> remarked:
>>>>>> On 3 Dec 2023 10:23, Roland Perry wrote:
>>>>>>> In message <ukhdge$2phim$1@dont-email.me>, at 08:16:14 on Sun, 3 Dec
>>>>>>> 2023, Tweed <usenet.tweed@gmail.com> remarked:
>>>>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>>>>> In message <3gsjmihrn2o0vvos598s3pt3p069e8c08c@4ax.com>, at 14:56:10 on
>>>>>>>>> Fri, 1 Dec 2023, Recliner <recliner.usenet@gmail.com> remarked:
>>>>>>>>>> On Fri, 1 Dec 2023 14:45:15 +0000, GB
>>>>>>>>>> <NOTsomeone@microsoft.invalid> wrote:
>>>>>>>>>>
>>>>>>>>>>> On 01/12/2023 09:42, Roland Perry wrote:
>>>>>>>>>>>
>>>>>>>>>>>> Even if I had such a vote, I would not cast it to implement quite such a
>>>>>>>>>>>> broken IT system.
>>>>>>>>>>>
>>>>>>>>>>> I think that everybody here agrees with you that the IT system is broken.
>>>>>>>>>>>
>>>>>>>>>>> Apart from the annoyance to people like yourself, it must cause much
>>>>>>>>>>> work within TFL sorting out the mess. And, there's no obvious reason for
>>>>>>>>>>> the slow updates of the fine system.
>>>>>>>>>>
>>>>>>>>>> One word explanation: Crapita
>>>>>>>>>>
>>>>>>>>>> https://www.capita.com/news/capita-operated-ultra-low-emission-zone-
>>>>>>>>>> expansion-launches-london
>>>>>>>>>>
>>>>>>>>>>> Nevertheless, you are going on a bit.
>>>>>>>>>>
>>>>>>>>>> Indeed so, but it's all new and shocking for Roland.
>>>>>>>>>>
>>>>>>>>>> This has actually been going on for years, and has been widely reported
>>>>>>>>>> in the media and in local groups:
>>>>>>>>>> https://www.reddit.com/r/london/comments/owj4ll/psa_your_private_plate_
>>>>>>>>>> can_make_you_car_seem_ulez/
>>>>>>>>>
>>>>>>>>> "they explained that DVLA doesn't give complete information when
>>>>>>>>> it's a private plate so they just make the car non-compliant"
>>>>>>>>>
>>>>>>>>> That's nonsense because TfL got the correct vehicle make and number from
>>>>>>>>> DVLA, which means they could also get the date of first registration,
>>>>>>>>> which confirms automatic compliance (only by six months, but one day
>>>>>>>>> would be sufficient).
>>>>>>>>>
>>>>>>>>> If it's been going on for years, then they've had plenty of time to fix
>>>>>>>>> it.
>>>>>>>>>
>>>>>>>>> I note a recent FOI response from TfL confirming they only update the
>>>>>>>>> database they check ANPR against "once a month", but failed to say when
>>>>>>>>> in the month, or answer the second part of the enquiry which was about
>>>>>>>>> its wider impact on personal plate holders.
>>>>>>>>>
>>>>>>>>> As it happens, my vehicle was issued with a V5 a month and a day before
>>>>>>>>> the alleged offence, and their database wasn't so out of date it had the
>>>>>>>>> wrong vehicle description. So this is a different type of glitch. If it
>>>>>>>>> had still said "Freelander" I'd be going about this quite differently.
>>>>>>>>>
>>>>>>>>> And part of the issue I have is the asymmetry - they say fines must be
>>>>>>>>> paid within 14 days (and in my case the notice spent the first 5 days in
>>>>>>>>> the post), but they give themselves a whole month to issue invalid
>>>>>>>>> notices.
>>>>>>>>>
>>>>>>>>> They also have an absolute deadline of responding to the notice by Xmas
>>>>>>>>> Eve, and although I accept it can be done online, the default is by
>>>>>>>>> post, and it's unclear if a proof-of-posting is evidence of "serving"
>>>>>>>>> the appeal, rather than the date they open the letter (which in any
>>>>>>>>> event they are stunningly unlikely to do on Xmas Eve, Xmas Day, or
>>>>>>>>> Boxing Day).
>>>>>>>>
>>>>>>>> Any entanglement with authorities that have some form of legislative
>>>>>>>> backing to their position is always asymmetric and not in favour of
>>>>>> the
>>>>>>>> individual. Just be thankful that you've not been accused of a serious
>>>>>>>> criminal offence that you didn't commit.
>>>>>>>
>>>>>>> Actually, TfL is committing a criminal offence because they are holding
>>>>>>> (and processing) needlessly inaccurate data, and that's a contravention
>>>>>>> of GDPR.
>>>>>>
>>>>>> I'm not sure VRMs identify individuals beyond the keeper and the
>>>>>> personal data in your case isn't wrong. Just some associated data.
>>>>>
>>>>> "just associated data" is the whole point.
>>>>>
>>>>> In the case of ULEZ PNs, it clearly has the keeper's name and address
>>>>> on, for example, which in the case in question is *correct* (as is the
>>>>> make and model of the vehicle), what's in error is the data they are
>>>>> holding which says that the keeper is driving a non-compliant vehicle,
>>>>> which is clearly not the case.
>>>>>
>>>> As I understand it, GDPR requires personal data to be accurate (in general
>>>> terms with exceptions). I don't see that the incorrect ULEZ classification
>>>> of a vehicle is personal data. The name and address of where to send the
>>>> penalty is, but that's different.
>>>
>>> Data processing also has to be fair and correct so this PN does not
>>> comply with GDPR.
>>>
>>>
>>
>> Do you have a cite for that last assertion? In its logical absurdity, I can
>> have data about moon orbits that I can process with an incorrect equation.
>> That produces incorrect data. That isn't an offence under GDPR.
>>
> Moon orbits are not a person. Roland is.

Property, of itself, is not personal data, nor is a record or document
describing set. This is clear from the application of the DPA in
Policing, especially when property is Found.
The loser of lost or stolen property is a piece of personal data but,
for example, a list of all lost/stolen jet skis is not PII.

it is all about characteristics of a natural person. So the letter
being sent is personal data, as is the issue of the PCN but the
characteristics of the vehicle aren't. (We'll leave the VRM out of
this conversation to avoid confusion)

On 09/12/2023 13:15, Rupert Moss-Eccardt wrote:
> On 9 Dec 2023 08:59, Coffee wrote:
>> On 08/12/2023 19:28, Tweed wrote:
>>> Coffee <martin.coffee@round-midnight.org.uk> wrote:
>>>> On 06/12/2023 10:27, Tweed wrote:
>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>> In message <kt9c10F931dU1@mid.individual.net>, at 19:29:35 on Tue, 5 Dec
>>>>>> 2023, Rupert Moss-Eccardt <nin@moss-eccardt.com> remarked:
>>>>>>> On 3 Dec 2023 10:23, Roland Perry wrote:
>>>>>>>> In message <ukhdge$2phim$1@dont-email.me>, at 08:16:14 on Sun, 3 Dec
>>>>>>>> 2023, Tweed <usenet.tweed@gmail.com> remarked:
>>>>>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>>>>>> In message <3gsjmihrn2o0vvos598s3pt3p069e8c08c@4ax.com>, at 14:56:10 on
>>>>>>>>>> Fri, 1 Dec 2023, Recliner <recliner.usenet@gmail.com> remarked:
>>>>>>>>>>> On Fri, 1 Dec 2023 14:45:15 +0000, GB
>>>>>>>>>>> <NOTsomeone@microsoft.invalid> wrote:
>>>>>>>>>>>
>>>>>>>>>>>> On 01/12/2023 09:42, Roland Perry wrote:
>>>>>>>>>>>>
>>>>>>>>>>>>> Even if I had such a vote, I would not cast it to implement quite such a
>>>>>>>>>>>>> broken IT system.
>>>>>>>>>>>>
>>>>>>>>>>>> I think that everybody here agrees with you that the IT system is broken.
>>>>>>>>>>>>
>>>>>>>>>>>> Apart from the annoyance to people like yourself, it must cause much
>>>>>>>>>>>> work within TFL sorting out the mess. And, there's no obvious reason for
>>>>>>>>>>>> the slow updates of the fine system.
>>>>>>>>>>>
>>>>>>>>>>> One word explanation: Crapita
>>>>>>>>>>>
>>>>>>>>>>> https://www.capita.com/news/capita-operated-ultra-low-emission-zone-
>>>>>>>>>>> expansion-launches-london
>>>>>>>>>>>
>>>>>>>>>>>> Nevertheless, you are going on a bit.
>>>>>>>>>>>
>>>>>>>>>>> Indeed so, but it's all new and shocking for Roland.
>>>>>>>>>>>
>>>>>>>>>>> This has actually been going on for years, and has been widely reported
>>>>>>>>>>> in the media and in local groups:
>>>>>>>>>>> https://www.reddit.com/r/london/comments/owj4ll/psa_your_private_plate_
>>>>>>>>>>> can_make_you_car_seem_ulez/
>>>>>>>>>>
>>>>>>>>>> "they explained that DVLA doesn't give complete information when
>>>>>>>>>> it's a private plate so they just make the car non-compliant"
>>>>>>>>>>
>>>>>>>>>> That's nonsense because TfL got the correct vehicle make and number from
>>>>>>>>>> DVLA, which means they could also get the date of first registration,
>>>>>>>>>> which confirms automatic compliance (only by six months, but one day
>>>>>>>>>> would be sufficient).
>>>>>>>>>>
>>>>>>>>>> If it's been going on for years, then they've had plenty of time to fix
>>>>>>>>>> it.
>>>>>>>>>>
>>>>>>>>>> I note a recent FOI response from TfL confirming they only update the
>>>>>>>>>> database they check ANPR against "once a month", but failed to say when
>>>>>>>>>> in the month, or answer the second part of the enquiry which was about
>>>>>>>>>> its wider impact on personal plate holders.
>>>>>>>>>>
>>>>>>>>>> As it happens, my vehicle was issued with a V5 a month and a day before
>>>>>>>>>> the alleged offence, and their database wasn't so out of date it had the
>>>>>>>>>> wrong vehicle description. So this is a different type of glitch. If it
>>>>>>>>>> had still said "Freelander" I'd be going about this quite differently.
>>>>>>>>>>
>>>>>>>>>> And part of the issue I have is the asymmetry - they say fines must be
>>>>>>>>>> paid within 14 days (and in my case the notice spent the first 5 days in
>>>>>>>>>> the post), but they give themselves a whole month to issue invalid
>>>>>>>>>> notices.
>>>>>>>>>>
>>>>>>>>>> They also have an absolute deadline of responding to the notice by Xmas
>>>>>>>>>> Eve, and although I accept it can be done online, the default is by
>>>>>>>>>> post, and it's unclear if a proof-of-posting is evidence of "serving"
>>>>>>>>>> the appeal, rather than the date they open the letter (which in any
>>>>>>>>>> event they are stunningly unlikely to do on Xmas Eve, Xmas Day, or
>>>>>>>>>> Boxing Day).
>>>>>>>>>
>>>>>>>>> Any entanglement with authorities that have some form of legislative
>>>>>>>>> backing to their position is always asymmetric and not in favour of
>>>>>>> the
>>>>>>>>> individual. Just be thankful that you've not been accused of a serious
>>>>>>>>> criminal offence that you didn't commit.
>>>>>>>>
>>>>>>>> Actually, TfL is committing a criminal offence because they are holding
>>>>>>>> (and processing) needlessly inaccurate data, and that's a contravention
>>>>>>>> of GDPR.
>>>>>>>
>>>>>>> I'm not sure VRMs identify individuals beyond the keeper and the
>>>>>>> personal data in your case isn't wrong. Just some associated data.
>>>>>>
>>>>>> "just associated data" is the whole point.
>>>>>>
>>>>>> In the case of ULEZ PNs, it clearly has the keeper's name and address
>>>>>> on, for example, which in the case in question is *correct* (as is the
>>>>>> make and model of the vehicle), what's in error is the data they are
>>>>>> holding which says that the keeper is driving a non-compliant vehicle,
>>>>>> which is clearly not the case.
>>>>>>
>>>>> As I understand it, GDPR requires personal data to be accurate (in general
>>>>> terms with exceptions). I don't see that the incorrect ULEZ classification
>>>>> of a vehicle is personal data. The name and address of where to send the
>>>>> penalty is, but that's different.
>>>>
>>>> Data processing also has to be fair and correct so this PN does not
>>>> comply with GDPR.
>>>
>>> Do you have a cite for that last assertion? In its logical absurdity, I can
>>> have data about moon orbits that I can process with an incorrect equation.
>>> That produces incorrect data. That isn't an offence under GDPR.
>>>
>> Moon orbits are not a person. Roland is.
>
> Property, of itself, is not personal data, nor is a record or document
> describing set. This is clear from the application of the DPA in
> Policing, especially when property is Found.
> The loser of lost or stolen property is a piece of personal data but,
> for example, a list of all lost/stolen jet skis is not PII.
>
> it is all about characteristics of a natural person. So the letter
> being sent is personal data, as is the issue of the PCN but the
> characteristics of the vehicle aren't. (We'll leave the VRM out of
> this conversation to avoid confusion)

GDPR includes data which could easily be combined with other data to
become personal. So, a record of where my car was seen is PII, because
it's trivial to discover who owns/keeps that car. Similarly, a record
of which websites my IP address has visited is PII, because my ISP knows
which customer had that IP address at the time.

Certes <Certes@example.org> wrote:
> On 09/12/2023 13:15, Rupert Moss-Eccardt wrote:
>> On 9 Dec 2023 08:59, Coffee wrote:
>>> On 08/12/2023 19:28, Tweed wrote:
>>>> Coffee <martin.coffee@round-midnight.org.uk> wrote:
>>>>> On 06/12/2023 10:27, Tweed wrote:
>>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>>> In message <kt9c10F931dU1@mid.individual.net>, at 19:29:35 on Tue, 5 Dec
>>>>>>> 2023, Rupert Moss-Eccardt <nin@moss-eccardt.com> remarked:
>>>>>>>> On 3 Dec 2023 10:23, Roland Perry wrote:
>>>>>>>>> In message <ukhdge$2phim$1@dont-email.me>, at 08:16:14 on Sun, 3 Dec
>>>>>>>>> 2023, Tweed <usenet.tweed@gmail.com> remarked:
>>>>>>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>>>>>>> In message <3gsjmihrn2o0vvos598s3pt3p069e8c08c@4ax.com>, at 14:56:10 on
>>>>>>>>>>> Fri, 1 Dec 2023, Recliner <recliner.usenet@gmail.com> remarked:
>>>>>>>>>>>> On Fri, 1 Dec 2023 14:45:15 +0000, GB
>>>>>>>>>>>> <NOTsomeone@microsoft.invalid> wrote:
>>>>>>>>>>>>
>>>>>>>>>>>>> On 01/12/2023 09:42, Roland Perry wrote:
>>>>>>>>>>>>>
>>>>>>>>>>>>>> Even if I had such a vote, I would not cast it to implement quite such a
>>>>>>>>>>>>>> broken IT system.
>>>>>>>>>>>>>
>>>>>>>>>>>>> I think that everybody here agrees with you that the IT system is broken.
>>>>>>>>>>>>>
>>>>>>>>>>>>> Apart from the annoyance to people like yourself, it must cause much
>>>>>>>>>>>>> work within TFL sorting out the mess. And, there's no obvious reason for
>>>>>>>>>>>>> the slow updates of the fine system.
>>>>>>>>>>>>
>>>>>>>>>>>> One word explanation: Crapita
>>>>>>>>>>>>
>>>>>>>>>>>> https://www.capita.com/news/capita-operated-ultra-low-emission-zone-
>>>>>>>>>>>> expansion-launches-london
>>>>>>>>>>>>
>>>>>>>>>>>>> Nevertheless, you are going on a bit.
>>>>>>>>>>>>
>>>>>>>>>>>> Indeed so, but it's all new and shocking for Roland.
>>>>>>>>>>>>
>>>>>>>>>>>> This has actually been going on for years, and has been widely reported
>>>>>>>>>>>> in the media and in local groups:
>>>>>>>>>>>> https://www.reddit.com/r/london/comments/owj4ll/psa_your_private_plate_
>>>>>>>>>>>> can_make_you_car_seem_ulez/
>>>>>>>>>>>
>>>>>>>>>>> "they explained that DVLA doesn't give complete information when
>>>>>>>>>>> it's a private plate so they just make the car non-compliant"
>>>>>>>>>>>
>>>>>>>>>>> That's nonsense because TfL got the correct vehicle make and number from
>>>>>>>>>>> DVLA, which means they could also get the date of first registration,
>>>>>>>>>>> which confirms automatic compliance (only by six months, but one day
>>>>>>>>>>> would be sufficient).
>>>>>>>>>>>
>>>>>>>>>>> If it's been going on for years, then they've had plenty of time to fix
>>>>>>>>>>> it.
>>>>>>>>>>>
>>>>>>>>>>> I note a recent FOI response from TfL confirming they only update the
>>>>>>>>>>> database they check ANPR against "once a month", but failed to say when
>>>>>>>>>>> in the month, or answer the second part of the enquiry which was about
>>>>>>>>>>> its wider impact on personal plate holders.
>>>>>>>>>>>
>>>>>>>>>>> As it happens, my vehicle was issued with a V5 a month and a day before
>>>>>>>>>>> the alleged offence, and their database wasn't so out of date it had the
>>>>>>>>>>> wrong vehicle description. So this is a different type of glitch. If it
>>>>>>>>>>> had still said "Freelander" I'd be going about this quite differently.
>>>>>>>>>>>
>>>>>>>>>>> And part of the issue I have is the asymmetry - they say fines must be
>>>>>>>>>>> paid within 14 days (and in my case the notice spent the first 5 days in
>>>>>>>>>>> the post), but they give themselves a whole month to issue invalid
>>>>>>>>>>> notices.
>>>>>>>>>>>
>>>>>>>>>>> They also have an absolute deadline of responding to the notice by Xmas
>>>>>>>>>>> Eve, and although I accept it can be done online, the default is by
>>>>>>>>>>> post, and it's unclear if a proof-of-posting is evidence of "serving"
>>>>>>>>>>> the appeal, rather than the date they open the letter (which in any
>>>>>>>>>>> event they are stunningly unlikely to do on Xmas Eve, Xmas Day, or
>>>>>>>>>>> Boxing Day).
>>>>>>>>>>
>>>>>>>>>> Any entanglement with authorities that have some form of legislative
>>>>>>>>>> backing to their position is always asymmetric and not in favour of
>>>>>>>> the
>>>>>>>>>> individual. Just be thankful that you've not been accused of a serious
>>>>>>>>>> criminal offence that you didn't commit.
>>>>>>>>>
>>>>>>>>> Actually, TfL is committing a criminal offence because they are holding
>>>>>>>>> (and processing) needlessly inaccurate data, and that's a contravention
>>>>>>>>> of GDPR.
>>>>>>>>
>>>>>>>> I'm not sure VRMs identify individuals beyond the keeper and the
>>>>>>>> personal data in your case isn't wrong. Just some associated data.
>>>>>>>
>>>>>>> "just associated data" is the whole point.
>>>>>>>
>>>>>>> In the case of ULEZ PNs, it clearly has the keeper's name and address
>>>>>>> on, for example, which in the case in question is *correct* (as is the
>>>>>>> make and model of the vehicle), what's in error is the data they are
>>>>>>> holding which says that the keeper is driving a non-compliant vehicle,
>>>>>>> which is clearly not the case.
>>>>>>>
>>>>>> As I understand it, GDPR requires personal data to be accurate (in general
>>>>>> terms with exceptions). I don't see that the incorrect ULEZ classification
>>>>>> of a vehicle is personal data. The name and address of where to send the
>>>>>> penalty is, but that's different.
>>>>>
>>>>> Data processing also has to be fair and correct so this PN does not
>>>>> comply with GDPR.
>>>>
>>>> Do you have a cite for that last assertion? In its logical absurdity, I can
>>>> have data about moon orbits that I can process with an incorrect equation.
>>>> That produces incorrect data. That isn't an offence under GDPR.
>>>>
>>> Moon orbits are not a person. Roland is.
>>
>> Property, of itself, is not personal data, nor is a record or document
>> describing set. This is clear from the application of the DPA in
>> Policing, especially when property is Found.
>> The loser of lost or stolen property is a piece of personal data but,
>> for example, a list of all lost/stolen jet skis is not PII.
>>
>> it is all about characteristics of a natural person. So the letter
>> being sent is personal data, as is the issue of the PCN but the
>> characteristics of the vehicle aren't. (We'll leave the VRM out of
>> this conversation to avoid confusion)
>
> GDPR includes data which could easily be combined with other data to
> become personal. So, a record of where my car was seen is PII, because
> it's trivial to discover who owns/keeps that car. Similarly, a record
> of which websites my IP address has visited is PII, because my ISP knows
> which customer had that IP address at the time.
>
>

In message <ktj7kcF65j2U1@mid.individual.net>, at 13:15:56 on Sat, 9 Dec
2023, Rupert Moss-Eccardt <nin@moss-eccardt.com> remarked:
>On 9 Dec 2023 08:59, Coffee wrote:
>> On 08/12/2023 19:28, Tweed wrote:
>>> Coffee <martin.coffee@round-midnight.org.uk> wrote:
>>>> On 06/12/2023 10:27, Tweed wrote:
>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>> In message <kt9c10F931dU1@mid.individual.net>, at 19:29:35 on Tue, 5 Dec
>>>>>> 2023, Rupert Moss-Eccardt <nin@moss-eccardt.com> remarked:
>>>>>>> On 3 Dec 2023 10:23, Roland Perry wrote:
>>>>>>>> In message <ukhdge$2phim$1@dont-email.me>, at 08:16:14 on Sun, 3 Dec
>>>>>>>> 2023, Tweed <usenet.tweed@gmail.com> remarked:
>>>>>>>>> Roland Perry <roland@perry.uk> wrote:
>>>>>>>>>> In message <3gsjmihrn2o0vvos598s3pt3p069e8c08c@4ax.com>, at
>>>>>>>>>>14:56:10 on
>>>>>>>>>> Fri, 1 Dec 2023, Recliner <recliner.usenet@gmail.com> remarked:
>>>>>>>>>>> On Fri, 1 Dec 2023 14:45:15 +0000, GB
>>>>>>>>>>> <NOTsomeone@microsoft.invalid> wrote:
>>>>>>>>>>>
>>>>>>>>>>>> On 01/12/2023 09:42, Roland Perry wrote:
>>>>>>>>>>>>
>>>>>>>>>>>>> Even if I had such a vote, I would not cast it to
>>>>>>>>>>>>>implement quite such a broken IT system.
>>>>>>>>>>>>
>>>>>>>>>>>> I think that everybody here agrees with you that the IT
>>>>>>>>>>>>system is broken.
>>>>>>>>>>>>
>>>>>>>>>>>> Apart from the annoyance to people like yourself, it must
>>>>>>>>>>>> work within TFL sorting out the mess. And, there's no
>>>>>>>>>>>>obvious reason for the slow updates of the fine system.
>>>>>>>>>>>
>>>>>>>>>>> One word explanation: Crapita
>>>>>>>>>>>
>>>>>>>>>>> https://www.capita.com/news/capita-operated-ultra-low-emission-zone-
>>>>>>>>>>> expansion-launches-london
>>>>>>>>>>>
>>>>>>>>>>>> Nevertheless, you are going on a bit.
>>>>>>>>>>>
>>>>>>>>>>> Indeed so, but it's all new and shocking for Roland.
>>>>>>>>>>>
>>>>>>>>>>> This has actually been going on for years, and has been
>>>>>>>>>>>widely reported
>>>>>>>>>>> in the media and in local groups:
>>>>>>>>>>>
>>>>>>>>>>>https://www.reddit.com/r/london/comments/owj4ll/psa_your_private_plate_
>>>>>>>>>>> can_make_you_car_seem_ulez/
>>>>>>>>>>
>>>>>>>>>> "they explained that DVLA doesn't give complete information when
>>>>>>>>>> it's a private plate so they just make the car non-compliant"
>>>>>>>>>>
>>>>>>>>>> That's nonsense because TfL got the correct vehicle make and
>>>>>>>>>>number from DVLA, which means they could also get the date of
>>>>>>>>>> which confirms automatic compliance (only by six months, but
>>>>>>>>>> would be sufficient).
>>>>>>>>>>
>>>>>>>>>> If it's been going on for years, then they've had plenty of
>>>>>>>>>>time to fix it.
>>>>>>>>>>
>>>>>>>>>> I note a recent FOI response from TfL confirming they only
>>>>>>>>>>update the database they check ANPR against "once a month",
>>>>>>>>>>but failed to say when in the month, or answer the second
>>>>>>>>>>part of the enquiry which was about its wider impact on personal plate holders.
>>>>>>>>>>
>>>>>>>>>> As it happens, my vehicle was issued with a V5 a month and a
>>>>>>>>>>day before the alleged offence, and their database wasn't so
>>>>>>>>>>out of date it had the wrong vehicle description. So this is
>>>>>>>>>>a different type of glitch. If it had still said "Freelander"
>>>>>>>>>>I'd be going about this quite differently.
>>>>>>>>>>
>>>>>>>>>> And part of the issue I have is the asymmetry - they say
>>>>>>>>>>fines must be paid within 14 days (and in my case the notice
>>>>>>>>>>spent the first 5 days in the post), but they give themselves
>>>>>>>>>>a whole month to issue invalid notices.
>>>>>>>>>>
>>>>>>>>>> They also have an absolute deadline of responding to the
>>>>>>>>>>notice by Xmas Eve, and although I accept it can be done
>>>>>>>>>>online, the default is by post, and it's unclear if a
>>>>>>>>>>proof-of-posting is evidence of "serving" the appeal, rather
>>>>>>>>>>than the date they open the letter (which in any event they
>>>>>>>>>>are stunningly unlikely to do on Xmas Eve, Xmas Day, or Boxing Day).
>>>>>>>>>
>>>>>>>>> Any entanglement with authorities that have some form of
>>>>>>>>>legislative backing to their position is always asymmetric and
>>>>>>>>>not in favour of the individual. Just be thankful that you've
>>>>>>>>>not been accused of a serious criminal offence that you didn't commit.
>>>>>>>>
>>>>>>>> Actually, TfL is committing a criminal offence because they are holding
>>>>>>>> (and processing) needlessly inaccurate data, and that's a contravention
>>>>>>>> of GDPR.
>>>>>>>
>>>>>>> I'm not sure VRMs identify individuals beyond the keeper and the
>>>>>>> personal data in your case isn't wrong. Just some associated data.
>>>>>>
>>>>>> "just associated data" is the whole point.
>>>>>>
>>>>>> In the case of ULEZ PNs, it clearly has the keeper's name and address
>>>>>> on, for example, which in the case in question is *correct* (as is the
>>>>>> make and model of the vehicle), what's in error is the data they are
>>>>>> holding which says that the keeper is driving a non-compliant vehicle,
>>>>>> which is clearly not the case.
>>>>>>
>>>>> As I understand it, GDPR requires personal data to be accurate (in general
>>>>> terms with exceptions). I don't see that the incorrect ULEZ classification
>>>>> of a vehicle is personal data. The name and address of where to send the
>>>>> penalty is, but that's different.
>>>>
>>>> Data processing also has to be fair and correct so this PN does not
>>>> comply with GDPR.
>>>>
>>>>
>>>
>>> Do you have a cite for that last assertion? In its logical absurdity, I can
>>> have data about moon orbits that I can process with an incorrect equation.
>>> That produces incorrect data. That isn't an offence under GDPR.
>>>
>> Moon orbits are not a person. Roland is.
>
>Property, of itself, is not personal data, nor is a record or document
>describing set. This is clear from the application of the DPA in
>Policing, especially when property is Found.
>The loser of lost or stolen property is a piece of personal data but,
>for example, a list of all lost/stolen jet skis is not PII.
>
>it is all about characteristics of a natural person. So the letter
>being sent is personal data, as is the issue of the PCN but the
>characteristics of the vehicle aren't. (We'll leave the VRM out of
>this conversation to avoid confusion)

In message <ul4mvh$2nq0d$1@dont-email.me>, at 15:54:25 on Sun, 10 Dec
2023, Tweed <usenet.tweed@gmail.com> remarked:

>Personal data only includes information relating to natural persons
>who: can be identified or who are identifiable, directly from the
>information in question; or who can be indirectly identified from that
>information in combination with other information.
>
>I don’t see how the ULEZ status of Roland’s car indirectly identifies him.

Albeit one of the boxes to tick to contest the PN is "the car was stolen
so I wasn't driving it", one of the things which makes DP professionals
tear their hair is people (geeks running small ISPs for example) arguing
things like "a log of my IP address and where I browsed can't possibly
be personal data because it might have been someone else using my
computer".

It's exactly the other way round: if it *might* have been me, it's
personal data, and needs processing lawfully.
--
Roland Perry

Roland Perry <roland@perry.uk> wrote:
> In message <ul4mvh$2nq0d$1@dont-email.me>, at 15:54:25 on Sun, 10 Dec
> 2023, Tweed <usenet.tweed@gmail.com> remarked:
>
>> Personal data only includes information relating to natural persons
>> who: can be identified or who are identifiable, directly from the
>> information in question; or who can be indirectly identified from that
>> information in combination with other information.
>>
>> I don’t see how the ULEZ status of Roland’s car indirectly identifies him.
>
> Albeit one of the boxes to tick to contest the PN is "the car was stolen
> so I wasn't driving it", one of the things which makes DP professionals
> tear their hair is people (geeks running small ISPs for example) arguing
> things like "a log of my IP address and where I browsed can't possibly
> be personal data because it might have been someone else using my
> computer".
>
> It's exactly the other way round: if it *might* have been me, it's
> personal data, and needs processing lawfully.

But all that is different to your erroneous penalty notice. I still don’t
see how you have a case under GDPR for that.

In message <ul7gaq$389su$1@dont-email.me>, at 17:19:22 on Mon, 11 Dec
2023, Tweed <usenet.tweed@gmail.com> remarked:
>Roland Perry <roland@perry.uk> wrote:
>> In message <ul4mvh$2nq0d$1@dont-email.me>, at 15:54:25 on Sun, 10 Dec
>> 2023, Tweed <usenet.tweed@gmail.com> remarked:
>>
>>> Personal data only includes information relating to natural persons
>>> who: can be identified or who are identifiable, directly from the
>>> information in question; or who can be indirectly identified from that
>>> information in combination with other information.
>>>
>>> I don’t see how the ULEZ status of Roland’s car indirectly
>>>identifies him.
>>
>> Albeit one of the boxes to tick to contest the PN is "the car was stolen
>> so I wasn't driving it", one of the things which makes DP professionals
>> tear their hair is people (geeks running small ISPs for example) arguing
>> things like "a log of my IP address and where I browsed can't possibly
>> be personal data because it might have been someone else using my
>> computer".
>>
>> It's exactly the other way round: if it *might* have been me, it's
>> personal data, and needs processing lawfully.
>
>But all that is different to your erroneous penalty notice. I still don’t
>see how you have a case under GDPR for that.

Then you will have to wallow in that ignorance, because I've already
explained it one more time than should be necessary.
--
Roland Perry