PrePass®

Bypass Event Data
Retention Policy

 Last Updated: Effective June 16, 2025.

Policy

It is the policy of the PrePass Safety Alliance (the “Alliance”) to endeavor to maintain bypass event data in a commercially reasonable manner that would not subject PrePass Customers to a higher level of regulatory compliance screening than non-PrePass Customers. To that end, the Alliance will not provide bypass event data attributable to a specific carrier or vehicle to a third-party without subpoena, as noted below in Section 4.0 or as otherwise authorized by the PrePass Customer (e.g. to a Customer vendor). The PrePass Safety Alliance owns and may retain all data generated and derived from access to and use of the PrePass Services offerings (“Services Data”), including but not limited to PrePass site screening event data (e.g. bypass event data), for a defined period of time for the purpose of operating the PrePass Services and program.

Purpose

To establish the procedures for collecting and retaining Services Data consisting of bypass event data.

Scope

This policy is applicable to everyone who will collect, retain or destroy PrePass Services Data consisting of bypass event data.

Procedures

1.0) Data Collection

In the normal course of PrePass site operations, all Services Data is owned, collected and retained by the Alliance. This Services Data is retained for multiple purposes and is used as the basis for (including, but not limited to): billing, site operations, and state and site activity reports that are periodically provided to participating state agencies.

2.0) 90 Day Data Retention

Services Data consisting specifically of bypass event data collected during the course of PrePass site operations may be retained for a period not to exceed 90 days beyond the specific event date. At that time, the Alliance may either (i) discard such bypass event data; or (ii) aggregate it at the Customer level by hashing the specific vehicle identification number (VIN). The Alliance may retain the Site ID, the Event Type (red light, green light, no light, station open or closed), month and day of the bypass event to the hour (not the exact time), count of the events, and the pull-in reason (random, weight, credentials, account status). Data will be de-identified with respect to a specific vehicle (as set forth herein) only after (a) payment by or on behalf of the specific carrier of an unprotested billing has been received by the PrePass Service Center, or (b) a protested billing has been resolved.

3.0) Cumulative Data Retention

All other Services Data and general data that does not relate a specific bypass event to a specific Customer vehicle may be retained indefinitely.

4.0) Exceptions

Upon request from a law enforcement agency, the President & CEO of PrePass Safety Alliance or the President & CEO’s designated representative may authorize the release of Services Data that is directly related to a felony criminal investigation or emergency, defined as:

    • an actual or impending situation that may cause injury, loss of life or destruction of property;
    • a situation in which a person is dangerous to him/herself or others or at imminent risk of severe physical injury or death; or
    • an event or situation that threatens serious damage to human welfare or terrorism which threatens damage to the security of the country.

5.0) Additional Services

Any Services Data request pertaining to other PrePass Services, such as PrePass Plus, will be referred to the authoritative source.