Temporary Privacy Notice – Car Park Occupancy Survey
(March/April 2026)
Belfast City Airport (BCA)
1. Purpose of this Notice
Belfast City Airport is carrying out a short-term (4‑day) vehicle occupancy survey within our car parks. Temporary fixed‑position cameras will be used to understand how many passengers typically travel in each vehicle. This notice explains what personal data may be collected, why it is processed, how it is protected, and how long it will be retained.
This notice sits alongside the main BCA Data Privacy Notice and reflects the specific processing authorised for this operational activity.
2. Who is collecting and processing my data?
- Data Controller: Belfast City Airport Limited (BCA)
- Data Processor: AtkinsRéalis UK Limited, acting on BCA’s instructions for this activity.
- Approved Sub‑Processor: MHC Traffic Ltd, responsible for temporary camera deployment and initial analytics under AtkinsRéalis control.
3. What data is being collected?
During this 4‑day period, cameras may capture:
- Images of vehicles entering/exiting car parks
- Incidental images of passengers in those vehicles
- Vehicle Registration Marks (VRMs), classified as personal data by the ICO (VRMs are processed only to support occupancy analytics and are not shared with BCA.)
No behavioural tracking, facial recognition, or automated decision-making is performed.
4. Why are we collecting this data? (Purpose of processing)
BCA is undertaking a one‑off occupancy analysis exercise to understand:
- Typical occupancy per vehicle
- Traffic flows and peak arrival patterns
- Future planning needs for car‑park operations
This processing is strictly limited to operational analytics. No marketing or profiling will take place.
5. Lawful basis for processing
Processing is carried out under:
UK GDPR Article 6(1)(f): Legitimate Interests
This is specifically BCA’s legitimate interest in understanding the utilisation of airport car‑park facilities and supporting future operational planning.
A Legitimate Interests Assessment (LIA) has been completed to ensure risks are proportionate and appropriately mitigated.
6. How will my data be used?
- The Processor and Sub‑Processor will extract only the data needed to calculate vehicle occupancy averages.
- BCA will only receive aggregated, anonymised results, not images, videos, or identifying information.
- No footage will be used for enforcement, behavioural monitoring, or security functions.
- No automated decision‑making or AI systems will be used for this processing.
7. How long will my data be kept?
In line with BCA’s instructions:
- Raw footage and identifiable data will be kept for no longer than 6 months.
- After this period, AtkinsRéalis and MHC must securely delete all footage and provide a deletion certificate to BCA.
BCA will retain only aggregated, anonymised occupancy results.
8. Who will my data be shared with?
Personal data captured through the cameras will not be disclosed to any organisation other than:
- AtkinsRéalis (Processor)
- MHC Traffic Ltd (Sub‑Processor)
No other third parties will receive any identifiable personal data.
There are no international transfers; all processing is conducted in the United Kingdom only.
9. Your rights under UK GDPR
You have the right to:
- Request access to your personal data
- Request rectification or erasure
- Object to the processing
- Request restriction of processing
- Make a complaint to the Information Commissioner’s Office (ICO)
If you wish to exercise any rights, please contact the BCA Data Protection Officer using the details below.
10. Contact details
Data Protection Officer
Belfast City Airport
Email: [email protected]
Postal: Sydenham Bypass, Belfast, BT3 9JH
11. How long will this notice remain published?
This Temporary Privacy Notice will remain on the BCA website for six (6) months, covering the full retention period applicable to this processing.
12. Updates to this Notice
If any element of the processing changes, BCA will update this notice accordingly, consistent with our main privacy‑notice change process.
Last Updated: 25.03.2026