Clean Air Zone ANPR privacy notices


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

On 16 March 2020, a ministerial direction pursuant to the Environment Act 1995 was issued to the 10 Greater Manchester local authorities (GM Local Authorities: The Borough Council of Bolton, Bury Metropolitan Council, Manchester City Council, Oldham Borough Council, Rochdale Metropolitan Borough Council, Salford City Council, Stockport Metropolitan Borough Council, Tameside Metropolitan Borough Council, Trafford Metropolitan Borough Council and Wigan Metropolitan Borough Council) by the Secretary of State for Environment Food and Rural Affairs, directing them to implement their local plan for delivering compliance with the statutory annual limits in relation to nitrogen dioxide concentrations in the shortest possible time.

The way that the GM Local Authorities intend to comply with the ministerial direction is by implementing the Greater Manchester Clean Air Plan, which includes the establishment and operation of a Clean Air Zone ("CAZ") Class C in its local authority area (“the CAZ Service”). In order to implement the GM Clean Air Zone, TfGM has been authorised to act in a coordinating and delivery role and to exercise the necessary functions in delivering the CAZ and supporting measures.

The categories of vehicles included in the CAZ, and minimum emission standards, are set by government in its Clean Air Zone Framework. A CAZ Class C means that when the Clean Air Zone becomes operational the following vehicles would pay a daily charge if they don’t meet emission standards:

  • Light goods vehicles, heavy goods vehicles, buses, coaches, hackney cabs, private hire vehicles and minibuses.

TfGM is the data controller for the data collected with Egis, our main supplier providing our Clean Air Service, who are a data processor, and Siemens, who is providing the ANPR system, a sub-processor.

What categories of personal data are used?

In preparation for the Greater Manchester Clean Air Zone, which is expected to go live from May 2022, Transport for Greater Manchester will be installing Automatic Number Plate Recognition (ANPR) cameras across Greater Manchester and collecting the following personal data:

  • Vehicle Registration Numbers (VRNs)
  • Images of immediate area

At this stage in the project (from August 2021) the purpose of the ANPR cameras is to support the development of the Clean Air Zone. Data will only be collected to measure the detection and accuracy of the cameras as well as test scenarios to prove the solution is working as expected.

There will be 850+ cameras installed acrossed Greater Manchester for the CAZ between August 2021 and April 2022.

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 a number of different legal bases under which processing of personal data may take place. In relation to the processing of VRMs using our ANPR cameras the following basis applies:

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

The GM Local Authorities are jointly subject to a Direction from the Secretary of State for the Environment, Food and Rural Affairs dated 16 March 2020 issued pursuant to section 85(5) of the Environment Act 1995 requiring them to implement a local plan for NO2 compliance for the areas for which they are responsible.

Each of the GM Local Authorities has via a delegation approved that the GMCA (acting by its officer, TfGM) is authorised to undertake arrangements that need to be undertaken to deliver the GM Clean Air Zone on behalf of the Local Authorities in accordance with TfGM’s existing constitutional arrangements.

How do we keep your information safe?

TfGM is committed to the security of information we collect, and we use reasonable measures to prevent unauthorised access to that information. We are required to demonstrate that our solutions meet the required levels of personal, procedural, policy, data, and technical security. We will only process personal information for the purposes it has been collected or subsequently authorised.

The data used for the Clean Air Zone is fully encrypted both at rest and when it is transmitted. All information is hosted within the UK. Cameras will be tested and monitored on a regular basis.

How long is information kept for?

The information collected during the camera installation and testing phase of the project will be stored for a maximum of 14 days in line with the Clean Air Certification of Approved Devices issues by the Vehicle Certification Agency.

When the Clean Air Zone becomes live in spring 2022, the retention period may be extended for example by a further two weeks to take into account the payment window for individuals to pay the fine and some contingency processes.

Who will we share your information with?

At this moment in time information will only be shared with Egis and Siemens, who are processing the information on behalf of TfGM for testing purposes.

At later stages in the programme as the Clean Air Zone begins to be deployed your information will be shared with other third parties in order to confirm compliance with the Clean Air Zone. This will include the Joint Air Quality Unit (JAQU), and the DVLA. Data sharing agreements will be put in place for the sharing of this information.

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.

Further information

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 the response from us, you can complain to the Information Commissioner’s Office. 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 General Data Protection Regulation (GDPR) can be found at the ICO website

This privacy notice will be updated as the Clean Air Zone implementation programme progresses.