CCTV Data Privacy Notice

CCTV Privacy Notice
Molekule – CCTV
This privacy notice was last updated on 24th May 2018.

1. What is the purpose of this Privacy Notice?
Your ‘personal data’ or ‘personal information’ is any piece of information that would allow us to identify you as an individual. The processing of personal data is governed by the EU General Data Protection Regulation (the “GDPR”) and national laws that implement the GDPR in each European Economic Area (“EEA”) country.

We take your privacy very seriously, and this document sets out what personal information we collect from you in relation to this service, how we intend to use it and what your rights in respect of that information are. By visiting our premises, you are accepting and consenting to the practices described in this Privacy Notice.

It is important that you read this Privacy Notice (together with any other privacy notice or fair processing notice we may provide you with on specific occasions when we are collecting or processing personal data about you) and we encourage you to keep copies of all such notices for your records.

Our work sites are not intended for children and we do not knowingly collect data relating to children.

2. Who controls your personal information, and how do you get in touch?
The controller of your personal information is Cuts Ice Limited, a company incorporated and registered in England and Wales under company number 07512911 (“we”, “us”, “our”). Cuts Ice Limited is a member of the Cuts Ice group comprising many different legal entities. This Privacy Notice is issued on behalf of Molekule in the Cuts Ice group, and you will interact with the brand via:



Should you have any query in respect of this Privacy Notice (including details of the group companies) or your personal information, you can contact us at the following:

Data controller

Cuts Ice Limited

Website

http://www.cutsice.com/

Address

Unit 2 Origin Business Park, Rainsford Road, Park Royal
London, NW10 7FW

Telephone

+44 208 960 6974

Email

privacy@cutsice.com


3. What information do we collect about you, and for what purpose?
We collect the following information from you to ensure your safety and that of our staff, as well as protect our offices from damage:

  • Your face and other identifying features in the video footage we record.

We do not collect any special categories of personal data about you or your representatives (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. How do we collect your personal information?
We collect your personal information through different methods, including:

  • Information you give us. When you enter one of our premises and are seen on the CCTV systems.
  • Information we automatically collect about you. We may automatically collect information if you walk / drive past our premises within an open public area that is covered by our CCTV cameras around our premises.

5. What is our legal basis for collecting and using your personal information?
We will use your personal information in the following ways and for the purposes set out below. We have identified our legitimate interests where appropriate.

Your information

Purpose

Legal basis

Your face and other identifying features in the video footage we record

Protecting your safety and that of our staff, as well as detecting and preventing crime

We need this information for our legitimate interests as the controller of this data (for the detection and prevention of crime, or health and safety on our premises)


6. What if you do not want to provide your personal information?
You do not have to provide your personal information to us. However, should you choose not to provide it, you may be unable to visit or use our premises.

7. How is your personal information protected?
We maintain strong physical, electronic and procedural safeguards to protect the confidentiality, integrity and availability of your personal information. We have taken appropriate security measures against illegal and/or unauthorised access to your personal information, and against the accidental loss of, or damage to, it.

8. Do we share your personal information with anyone?
Data is shared as part of the usage of the CCTV system with several parties outside of Cuts Ice that allow us to process your data.  These parties, and the purposes for sharing the data, are set out below:

CCTV solution provider

These companies provide the equipment and maintenance for the CCTV equipment that we use

CCTV Monitoring company

These companies have remote viewing capabilities of our cameras and ensure that they are monitored when we are not here.


We may also need to share your personal information with the following in limited circumstances:

  • IT security providers;
  • Insurers;
  • External advisors (for example solicitors or auditors); and
  • Public authorities or law enforcement.

If we sell or buy (or plan to sell or buy) any business or assets or seek investment from a third-party investor, we may disclose your personal data to the investor or prospective seller or buyer of such business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

Any time we provide access to your personal information to someone else, we will ensure that it is adequately secured to protect your privacy and that they comply with the requirements of the applicable data protection legislation.

9. Will your personal information be transferred outside of the EEA?
If you are a resident of a country in the EEA, we may need to transfer your personal information outside of the EEA, for example where our data storage facilities or processing locations are in another country. 
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by putting adequate, legally-approved safeguards in place, including at least one of the following: 

  • we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

If you would like more information about our safeguards, please contact us using the details inserted in Section 2 above.

10. How long do we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we hold it for, including for the purposes of satisfying any legal, accounting or reporting requirements. In general, we will need to keep the information that we collect from you for the following periods of time:

Your information

Retention Period

Your face and other identifying features in the video footage we record

The information will be retained for eight (8) weeks.  All CCTV operations are conducted in line with the recommendations from the information commissioner under its CCTV code of practice, and under the Protection of Freedoms Act 2012.


We may sometimes need to keep a copy of your personal information for a longer period, for example in the event of an incident, to investigate a data breach or to comply with legal requirements. We will never keep your personal information for longer than we consider necessary.
In all cases, your personal information will be securely destroyed once the retention periods described above expire.

11. What are your rights in respect of your personal information?
You have rights in respect of the personal information we hold on you, including the right to ask us to:

  • inform you on how we collect and use it (this Privacy Notice is designed to do that);
  • provide you with a copy of any information we hold on you
  • request the transfer of it to you or a third party; and

You can also object to our use of your personal information for our legitimate purposes at any time.


Should you want to exercise any of those rights, please contact us using the details set out in Section 2 above. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Where a person makes an access requests and there are other data subjects such as people or number plates on the same footage or images, the requested footage or images will be subject to a blurring process to ensure the rights to privacy of the other person.  Restrictions of access do apply where the blurring process of the data cannot hide CCTV footage of the other subjects the data will not be released to ensure the protection of the other person’s right to privacy.

12. Will we do anything else with your information in the future?
We may use your image for the prevention of crime within all our sites and provide this to the security company that protects our sites to be able to identify you if we do not wish to allow you access to our premises.

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new, unrelated purpose, we will endeavour to notify you and communicate the legal basis which allows us to do so before starting any new processing.

The exception to this is where use of the personal information is required or permitted by law e.g. to a recall of any of our products, updated allergy advice or for another legal reason that may require us to contact you. In this case, we may process your personal information without your knowledge or consent.

13. You have the right to complain to us or our supervisory authority
You also have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office, which can be contacted at the following:

Supervisory Authority

UK Information Commissioner’s Office

Website

https://ico.org.uk/concerns/

Address

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom

Telephone

0303 123 1113

Email

https://ico.org.uk/global/contact-us/email/


14. Changes to this Privacy Notice and your duty to inform us of changes
We may need to make changes to this Privacy Notice in the future (for example, to comply with new legal requirements).

Where that is the case, we will provide you with a revised Privacy Notice on our website, which you will be able to access. If required by law, we will seek your prior approval before revising this Privacy Notice.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.