Greater Manchester Clean Air Plan privacy policy

Updated April 2023

The Greater Manchester Clean Air Plan

In July 2017, the UK government published the UK plan for tackling roadside nitrogen dioxide (NO2) concentrations. The plan sets out several national and local measures that needed to be taken, including the development by local authorities of local plans to tackle the causes of air pollution.

In March 2020, the government instructed all ten Greater Manchester (GM) councils (Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside, Trafford and Wigan) to introduce a charging Clean Air Zone (CAZ) to tackle harmful levels of air pollution and achieve compliance with legal standards by 2024 at the latest. This direction has now been withdrawn and means that the GM Clean Air Plan (GM CAP) measures that had been approved by the GM local authorities after the statutory consultation, including a GM-wide CAZ Category C Zone, are under review.

A new government direction dated 8th February 2022 requires the 10 GM local authorities to bring nitrogen dioxide on local roads to within legal limits as soon as possible and by no later than 2026 and to work with government to develop a new plan that will clean up our air while protecting livelihoods.

On 1 July 2022 the Air Quality Administration Committee (AQAC), a joint committee of the ten GM Local Authorities with the Greater Manchester Combined Authority (GMCA), noted the 'Case for a new Greater Manchester Clean Air Plan' document and associated appendices would be submitted to the Secretary of State on the 1 July as a draft document subject to any comments of Greater Manchester local authorities. The following AQAC meeting confirmed the final submission and the Secretary of State was notified of the change in status.

The 'Case for a new Greater Manchester Clean Air Plan' sets out evidence supporting an investment-led Clean Air Plan with no charging Clean Air Zone as the best solution to address the NO2 air pollution problem.

In January 2023, government asked for additional evidence to support GM’s case for an investment-led, non-charging Clean Air Plan.

Government has also asked GM to provide modelling to understand how GM’s case for an investment-led, non-charging Clean Air Plan performs (in terms of delivering compliance with legal nitrogen dioxide levels) against the ‘benchmark’ of a charging Clean Air Zone. It is expected that this additional evidence, requiring detailed modelling, will be submitted to government by the end of June 2023.

Once full, formal government feedback is received on the Clean Air Plan following the submission of this additional evidence, timescales will be considered for a public consultation on the plan and will determine what will happen to the Clean Air Zone signage. The final decision on a charging Clean Air Zone will be made by Government.

Once GM’s local authorities meet their air quality legal limits, the Automatic Number Plate Recognition (ANPR) cameras will no longer be used for Clean Air Plan purposes. GM wants to work with government to consider whether they could be used for potential law enforcement activity related to the detection of crime. There would be a full public consultation on any such measures. Each of the GM Local Authorities has via a delegation approved that the GMCA (acting by its officer, Transport for Greater Manchester (TfGM)) is authorised to undertake arrangements that need to be undertaken to deliver the GM CAP on behalf of the 10 GM Local Authorities in accordance with TfGM’s existing constitutional arrangements.

For more information on Clean Air Zones please visit the GOV.UK clean air zones guidance page. This is separate to the GM Clean Air Financial Support Scheme.

GM Clean Air Plan privacy notice

The GM CAP privacy notice supplements TfGM’s general privacy notice and explains how we will process and share personal data for the purposes of the GM CAP. TfGM and the ten GM local authorities are a joint data controller with the Joint Air Quality Unit (JAQU) and for personal data processed by JAQU, who are a joint unit of the Department of Transport (DfT) and the Department for Environment, Food and Rural Affairs (Defra) which is overseeing the UK plan for tackling roadside NO2 concentrations.

On behalf of the 10 GM LA’s TfGM has procured Egis Projects SA as a data processor to deliver the GM CAZ service.

This privacy notice deals with the personal data that TfGM processes to deliver the GM CAP, and what information is shared with JAQU as joint controllers. Should you wish to know more about how JAQU processes and shares your personal data please refer to its privacy notice.

What personal data is being collected and how is it used?

Customer contact centre

If you phone the Customer Contact Centre to make any enquiries concerning GM CAP, the following information may be requested from you to provide resolution to queries and support:

  • First name
  • Surname
  • Phone number
  • Email address
  • Address
  • Postcode

Vehicle Registration Numbers (VRNs) and Automatic Number Plate Recognition (ANPR) Cameras

The ANPR cameras installed for the GM CAP are being utilised to better understand the current vehicle fleet on Greater Manchester’s roads and their emissions. This is helping GM understand how vehicle fleets have naturally renewed over the development of the GM CAP. Where ANPR cameras are next to air quality monitoring stations, we can also analyse and understand how specific vehicle types might be contributing to overall emissions.

TfGM together with GM LAs is the joint data controller for data processed by the ANPR cameras. The cameras are supplied and operated by Yunex Traffic who are a sub-processor of Egis who process this information on behalf of TfGM.

TfGM does not have access to the details of registered keepers of the vehicle images captured on the ANPR cameras which collect the following data:

  • Vehicle Registration Numbers (VRNs) captured by ANPR images
  • Images of the immediate area
  • Dates, times and location of vehicles captured

VRN details may be matched using the publicly available DVLA Vehicle Enquiry Service to enrich the data with information on vehicle type, fuel and age. At this point the VRN data is then removed from the dataset and only the anonymised data is recorded.

The matching process only occurs if necessary for bespoke analytical purposes and does not occur as soon as the data is collected. Data is held on a secure server with the ANPR subcontractor, with all records deleted after 6 months. Therefore there is a period of time prior to the matching where VRN details are retained. During this period, law enforcement agencies are able to submit a request for this information to support ongoing investigations. TfGM require that sufficient information is submitted to verify that any disclosure is proportionate. TfGM are not able to identify registered keepers of vehicles.

TfGM will use the data to help gain a better understanding of the current vehicle fleet on the city-region's roads and their emissions and to understand how vehicle fleets have naturally renewed over the development of the Clean Air Plan, and what impact the pandemic may have had.

Your VRN will also be collected if you use the government vehicle checker to check if a vehicle is compliant. This is operated by JAQU which will be the data controller of this information. You can access further information in relation to the vehicle checker by going to the GOV.UK website and reviewing JAQU’s privacy notice.

Who will we share your information with?

In order to inform the GM CAP review with government, information may be lawfully shared with the following for further evaluation and reporting:

  • Suppliers working with or on behalf of TfGM who are processing information on behalf of TfGM for testing purposes and informing the new GM CAP.
  • Other government departments such as the DfT, the DVLA and JAQU.
  • Other GM Local Authorities.

Should the government decide that a CAZ is to be included in any revised GM CAP, then for the purposes of operating a CAZ information will be shared with other third parties in order to confirm compliance with any CAZ requirements. This will include JAQU, and the DVLA.

Data sharing agreements are in place for the sharing of this information and further agreements or variations may be required as the project progresses.

We may need to share some personal information with other third parties who are assisting us to deliver the GM CAP. Further privacy notices will be available for the sharing of this information.

This privacy notice will be updated as the GM Clean Air Plan progresses, and we will provide you with a new privacy notice when we make any substantial updates.

NO2 evaluation data

In order for TfGM and JAQU to assess and monitor information to inform the GM CAP, TfGM needs to gather 'real time' data and understand the type of vehicles travelling on local roads within the GM administrative boundary to develop a new plan that will clean up our air while protecting livelihoods.

Under what legal basis does the processing of personal data take place?

The UK General Data Protection Regulation (GDPR) and Data Protection Act 2018 provide for several different legal bases under which processing of personal data may take place. In relation to the processing of the personal data for the GM CAP contact centre the following basis applies:

  • Article 6 (1)(e) processing is necessary for the performance of a task carried out in the public interest and in the exercise of official authority vested in DfT and Defra as partners in JAQU and TfGM and the local authorities to deliver a new Clean Air Plan.

For any special category personal data that may be processed the lawful basis is:

  • Article 9(2)(g) of the UK GDPR (processing is necessary for reasons of substantial public interest and is authorised by domestic law (see section 10 of the Data Protection Act 2018).

In relation to the processing of VRMs using the ANPR cameras the following legal basis applies:

  • Article 6 (1) (c) processing is necessary for compliance with a legal obligation.

The ANPR cameras were installed pursuant to the Transport Act 2000 (TA 2000) which includes specific powers to install and maintain or authorise the installation and maintenance of any equipment used or to be used in connection with the operation of a road user charging scheme (see s.176(1) TA 2000). The ANPR cameras are currently being used for monitoring and evaluation purposes and this use was commenced in anticipation of the commencement of the CAZ under the Transport Act 2000 powers.

The final decision on a charging Clean Air Zone will be made by Government.In the event of a decision that there will be no charging CAZ, the GM local authorities may rely on the general power of competence in the Localism Act 2011 to install, maintain and operate the ANPR cameras, subject to compliance with relevant data protection legislation and the Surveillance Code. This purpose would be outside the remit of the GM CAZ.

How long is information kept for?

The information collected to monitor and inform the new plan is kept for the minimum period necessary to fulfil the purposes it is collected it for. Information will not be kept for longer than necessary.

Any images captured on ANPR cameras are kept for a maximum of 14 days in line with the Clean Air Zone Certification of Approved Devices [CoAD] issued by the Vehicle Certification Agency [VCA]. The VCA is an executive agency, sponsored by the DfT.

How do we keep your information safe?

We are committed to keeping your information safe and protected from accidental loss or alteration, inappropriate access, misuse or theft. As well as technical physical and organisational controls, we recognise that a well-trained, informed and security-alert workforce minimises privacy risks from human error and/or threats from malicious actors.

We require our service providers to implement appropriate industry-standard security measures, and only allow them to process personal information for specified purposes as written in our contracts with them.

Your rights as a data subject (any individual person who can be identified)

The UK GDPR gives you the following rights over your information:

  • Your right to get copies of your information. You have the right to ask for a copy of any information about you that is used.
  • Your right to get information corrected. You have the right to ask for any information held about you that you think is inaccurate to be changed.
  • Your right to limit how your information is used. You have the right to ask for the use of any information held about you to be restricted. For example, you can ask this where you think the information TfGM is using is inaccurate.
  • Your right to object to your information being used. You can ask for any information held about you not to be used. This is not an absolute right and TfGM may need to continue to use your information. We will tell you why if this is the case.
  • Your right to get your information deleted. You can ask for any information held about you to be deleted. This is not an absolute right and TfGM may need to continue to use your information. We will tell you why if this is the case.

For further information about the GM Clean Air Plan or for complaints or enquires please visit

If you require further information about UK Clean Air Zones, please contact JAQU.

For further information about anything in this privacy notice, to find out what information we hold about you, or if you wish to exercise any of your other information rights, please contact us at

If you are not satisfied with any response from us in relation to the processing of your personal data, you can complain to the Information Commissioner’s Office (ICO). For further details on this and your information rights please visit the Information Commissioner’s website.

Further information about data privacy and your rights under the GDPR can be found at the ICO website: