May 112011
 
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Last February, I learned that the Evergreen Point Floating Bridge (the bridge over Lake Washington on State Route 520) would soon become a tollway, that there would not be any tollbooth for the bridge, and that drivers would have three options for payment: 1) create an account with Washington State Department of Transportation (WSDOT) and affix an RFID tag to the associated vehicle so that it can be identified when crossing the bridge, 2) create an account with WSDOT and rely on a license plate scanner (similar to that which Seattle Police Department use) to identify the associated vehicle when it crosses, or 3) rely on a license plate scanner to identify the vehicle and have a bill mailed to the registered owner.  Option #3 is the most expensive.  #1 is the least expensive.  I’ve since learned of another option, an “unregistered pass account” that can be created anonymously, prepaid, and associated with an RFID tag.

News of this system concerned me, as it seemingly prevented anonymous travel across the bridge.  I don’t believe our government should be keeping records of our travels, regardless of the intended purpose of those records.  I would happily slow down and pay a cash toll if by doing so I could maintain the ability to travel around without having to identify myself to anyone and without someone keeping a log of where I’ve been.  I generally trust the people at WSDOT to not to misuse that information, but I would prefer not to need to trust them — not to mention everyone with access to that information in the future — with it.

In a WSDOT e-mail newsletter I received later in February, a representative wrote, “Got a burning question about I-5, SR 99, SR 520 or I-90? I bet I can find the answer. Send your Seattle area highway related questions or comments to Broch Bender at Benderb@wsdot.wa.gov.”  I had several burning questions, and took him up on the offer.  He replied, “You’ve raised some interesting questions.  Unfortunately, I do not have any of the answers.  Don’t fret.  I am copying Janet Matkin at our SR 520 Good to Go! Tolling office.  I bet she’ll be able to find them out for you.”

Ms. Matkin reported in March that she was busy opening a new customer service center.  In early May, just as I was considering either contacting her superior or filing public records requests for related e-mails to get to the bottom of things, she responded thoroughly.  My questions and her answers follow (hyperlinks added).

Q: What is WSDOT’s data retention policy for information about Good to Go passes and license plates scanned on the SR 520 bridge?
A: We hold images of license plates for one year and we hold toll transactions for five years.

Q: Is the license plate of every vehicle which crosses the SR 520 bridge photographed (i.e., is a digital image captured)?  If not, which ones are?
A: The license plates are photographed for every vehicle crossing the bridge.

Q: After optical character recognition (OCR) is performed to recognize license plates, is the image from which the characters are recognized (i.e., the whole picture with the plate, the rest of the vehicle, etc.) stored?
A: Photos are only taken of the license plates, not the entire vehicle, and not the driver of the vehicle. The photo of the license plate is stored following the data retention policies.

Q: What is the manufacturer and model of WSDOT’s automated license plate recognition (ALPR) equipment used to identify vehicles on the SR 520 bridge?
A: The cameras used to capture license plates is made by JAI Pulnix.  The part/identifying number is 30104436 VIS 400 Camera Assembly. The OCR Engine being used is JAI Pulnix OTS OCR.

Q: What is the manufacturer and model of WSDOT’s radio frequency identification (RFID) equipment used to identify vehicles on the SR 520 bridge?
A: The manufacturer is SiRIT. The model is 5204.

Q: In what manner has WSDOT announced to the public that a record of their travel on the SR 520 bridge will be created and retained?
A: The Customer Agreement that all Good To Go! account holders must agree to as part of the account sign up process includes the following section:

9.0 Privacy Policy

9.1 The Good To Go! Privacy Policy is subject to the requirements of state and federal law and may be amended at any time in accordance with applicable statutory requirements. Notice of any changes to this Privacy Policy will be available via e-mail, on your account statement and/or at the walk-in Customer Service Center(s). Notices will also be posted on the web site.

9.2 Information collected by the Customer Service Center related to your account will not be released except under the following circumstances:

a. In response to a court order for specific information.
b. At your request as the individual account holder with proper identification.
c. As necessary to collect unpaid tolls, fees and penalties.
d. Or as otherwise required by law.

9.3 More information on the privacy guidelines can be found at the Washington State Department of Transportation’s web site at http://wsdot.wa.gov.

This question and answer are part of our Common Questions on the web page:

Will my privacy be protected?

Yes. Good To Go! electronic tolling Passes use radio frequency identity chips, which do not hold any personal information. For Pay By Mail, only photos of the vehicle are taken, not the driver or occupants. All personal data, including name, address and payment information, is kept confidential and privacy is protected by law. Under no circumstances is individual customer information disclosed for use by marketing firms.

We also have information on the Account Types web page that outlines an anonymous account option:

Unregistered Pass Account

This account is only available through the Customer Service Center, and must be set up in person. This account does not require you to provide any identifying contact information. You may choose to provide an email address to receive statements, and may establish read-only online account access. At least one Pass must be assigned to the account. Please note that any toll transactions that cannot be posted to the account will be billed to the registered vehicle owner via Pay By Mail. Pre-paid funds cannot be refunded if an unregistered account is closed.

Q: What protections are in place for the database of travel information collected by WSDOT’s RFID and ALPR readers?
A: WSDOT follows the direction of the Department of Information Services and Information Services Board. They are the ones that determine what security is required based on the information being handled.

Q: Does WSDOT collect information about when and where people travel at points other than the SR 520 bridge entrances?
A: The Good To Go! Passes (transponders) are only used for toll collection purposes. WSDOT installs these readers only at tolling points (currently on the Tacoma Narrows Bridge and on SR 167 between Renton and Auburn). The read range of Good To Go! Passes is 32 feet at most.

Q: Under what circumstances will WSDOT share information collected via RFID and ALPR scanners with outside parties?
A: Here are the applicable codes:

RCW 46.63.160 (6b)

The department of transportation may not sell, distribute, or make available in any way, the names and addresses of electronic toll collection system account holders.

Effective upon secretary’s certification for statewide CSC and photo tolls (which will occur when all of the new systems have been tested and approved, prior to the start of tolling on the SR 520 bridge)

RCW 46.63.160 (6a) (6c)

Photo toll systems may take photographs, digital photographs, microphotographs, videotapes, or other recorded images of the vehicle and vehicle license plate only.

Notwithstanding any other provision of law, all photographs, digital photographs, microphotographs, videotape, other recorded images, or other records identifying a specific instance of travel prepared under this chapter are for the exclusive use of the tolling agency for toll collection and enforcement purposes and are not open to the public and may not be used in a court in a pending action or proceeding unless the action or proceeding relates to a civil penalty under this chapter. No photograph, digital photograph, microphotograph, videotape, other recorded image, or other record identifying a specific instance of travel may be used for any purpose other than toll collection or enforcement of civil penalties under this section. Records identifying a specific instance of travel by a specific person or vehicle must be retained only as required to ensure payment and enforcement of tolls and to comply with state records retention policies.

She didn’t exactly answer that last question. “Not withstanding any other law” leaves open the possibility that there are other laws which allow or require disclosure. I’ll follow up.

WSDOT answer questions about privacy and records of SR 520 bridge crossings by Phil Mocek, unless otherwise expressly stated, is licensed under a Creative Commons Attribution-ShareAlike 4.0 International License.

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  4 Responses to “WSDOT answer questions about privacy and records of SR 520 bridge crossings”

  1. They have something like this in Florida. I have yet to figure out how they charge (a) vehicles with U.S. plates from another state and (b) non-U.S. (typically Canadian) vehicles with out of country plates. Any idea how that will work in Washington?

    • I haven’t heard or read about how WSDOT plan to handle vehicles licensed outside of Washington. I’ll e-mail you if I come across related information.

  2. It sounds like the DoT stores the license plate photo with the RFID scan for every car, even for “unregistered pass” accounts. This effectively makes these “unregistered pass” accounts not anonymous, since the DoT has contact (car registration) information available whenever the pass is used.

    If you cross the 520 bridge, and the cameras can read your license plate, a record of the trip will exist for a year, and it likely can be found quickly by searching on your plate number.

    If you use an “unregistered” pass, the DoT can associate that pass with a car (and registered owner) by simply looking up the license plate picture that was taken at the same time the RFID was scanned.

    To cross the 520 “anonymously” and legally, you will need to get an “unregistered pass”, and then find a way to make your license plate not readable by the cameras, but still readable by police and other humans (a requirement of driving on the roads).

    Alternatively, cross only in rental cars that you rented anonymously (very hard to do) with an unregistered pass.

    Perhaps it is time to give up on privacy http://www.wired.com/wired/archive/9.12/surveillance_pr.html

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