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FMCI CCTV PRIVACY NOTICE
FMCI (Future Mobility Campus Ireland, we, us or our) use Closed Circuit Television (“CCTV”) and its associated technology in the monitoring of both internal and external environs of the premises, under the remit of Future Mobility Campus Ireland (“FMCI”).
We take privacy very seriously. In this privacy notice we explain what data we capture and record with our CCTV system. This notice is meant for to all permanent and temporary employees, independent contractors, subcontractors or any person with CCTV responsibilities, including third parties.
1. General Principles
FMCI has a statutory responsibility for the protection of its property and assets as well providing a sense of security to its employees, clients and other stakeholders (including visitors). As such, CCTV is an important and essential system that is in place in and around the FMCI Control Centre (‘Control Centre’) to assist in maintaining the good order and security of the facility.
FMCI owes a duty under the provisions of Safety, Health and Welfare at Work Act 2005 and associated legislation and utilises CCTV systems as an added mode of security and surveillance to assist with its compliance with its statutory obligations.
The use of the CCTV system will be conducted in a professional, ethical and legal manner and any diversion of the use of CCTV security technologies for other purposes is prohibited by this policy e.g. CCTV will not be used for monitoring employee performance or monitoring based on characteristics and classifications contained in equality (race, gender, etc.).
All CCTV systems and associated equipment will be required to be compliant with this policy. Recognisable images captured by CCTV systems are “personal data.” They are therefore subject to the provisions of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
2. Who we are?
Future Mobility Campus Ireland (FMCI) is a company that has been established to create a space for organisations to research, develop and test innovative mobility solutions. FMCI has created a “lab” type environment within the Shannon Free Zone that will be accessible to organisations testing new methods of autonomous transport. Our address is Bay 80, Shannon Free Zone, Shannon, Co. Clare, Ireland, V14 WV82.
3. What personal data do we collect?
The primary purpose of CCTV in and around the Control Centre is:
- for the safety and security of employees, clients and other stakeholders (including visitors).
- to monitor access and circulation in the premises and ensure safety and security in the surrounding area, e.g. car parks, etc.
- to deter those having criminal intent and to help reduce the fear of crime.
- to assist, FMCI and/or the relevant authorities, in the detection and investigation of any events or crime if occurred.
- to give confidence to FMCI employees and other stakeholders that they are in a safe and secure environment.
- to improve and provide information relating to health and safety matters.
- to monitor lab testing sessions.
- following an incident, footage/images may be used for training with the individual employee involved in the specific incident.
4. How long do we store your personal data for?
The CCTV system with the images/recordings will be stored in a secure environment with a log of access kept by authorised personnel. Access will be restricted to authorised personnel. Supervising the access and maintenance of the CCTV System is the responsibility of the Chief Operations Officer. When CCTV recordings are being viewed, access will be limited to authorised individuals on a need-to-know basis.
Images and recordings are stored for a period not longer than 30 days and will then be erased unless required as part of an ongoing investigation or court or similar proceedings.
5. How do we use personal data?
The primary purpose of CCTV in and around the Control Centre is:
- for the safety and security of employees, clients and other stakeholders (including visitors).
- to monitor access and circulation in the premises and ensure safety and security in the surrounding area, e.g. car parks, etc.
- to deter those having criminal intent and to help reduce the fear of crime.
- to assist, FMCI and/or the relevant authorities, in the detection and investigation of any events or crime if occurred.
- to give confidence to FMCI employees and other stakeholders that they are in a safe and secure environment.
- to improve and provide information relating to health and safety matters.
- to monitor lab testing sessions.
- following an incident, footage/images may be used for training with the individual employee involved in the specific incident.
We may disclose personal data for the purposes we explain in this notice to our advisors (e.g., legal, financial, business or other advisors) and third parties permitted by law (e.g., the police, regulators, government agencies, or to judicial or administrative authorities).
6. What legal basis do we have for processing your personal data?
FMCI has a statutory responsibility for the protection of its property and assets as well providing a sense of security to its employees, clients and other stakeholders (including visitors). As such, CCTV is an important and essential system that is in place in and around the FMCI Control Centre (‘Control Centre’) to assist in maintaining the good order and security of the facility.
FMCI owes a duty under the provisions of Safety, Health and Welfare at Work Act 2005 and associated legislation and utilises CCTV systems as an added mode of security and surveillance to assist with its compliance with its statutory obligations.
7. How do we share personal data?
Access to the CCTV system and images will be restricted to authorised individuals that require access in order to achieve the purposes of using the equipment.
Disclosure of the recorded images to third parties shall only be made in limited and prescribed circumstances. Circumstances in which disclosure is appropriate would, for example, include:
- a formal written request from a member of An Garda Síochána, for disclosure of images, on the grounds that the images are likely to be of use for the investigation of a particular offence.
- a requirement under any enactment, rule of law or court order to disclose the images.
- if required by the FMCI’s legal representatives if a case/action is being taken against FMCI/employee/client/stakeholder.
- to third party providers who provide security services to FMCI, e.g. to redact footage.
- to data subjects (or their legal representatives), pursuant to an access request.
- to FMCI’s insurance company where the insurance company requires same in order to pursue a claim for damage done to the insured property.
If access and disclosure of images is required, FMCI will ensure all third parties whose images are not required for the purpose stated, should be obscured by pixilation or other acceptable distortion/editing techniques, i.e. anonymised. This section does not negate the requirement to identify witnesses to any event.
Under Article 15 of the GDPR, data subjects (including employees) have the right to obtain from FMCI a copy of their personal data being processed. CCTV images are in scope for a subject access request.
Third Party Security Companies: We may disclose personal data for the purposes we explain in this notice to our advisors (e.g., legal, financial, business or other advisors) and third parties permitted by law (e.g., the police, regulators, government agencies, or to judicial or administrative authorities).
Where a third party is responsible for providing certain services to FMCI in relation to CCTV, FMCI will ensure the following:
- there is a contractual relationship between FMCI and the third party.
- the third party has given appropriate guarantees regarding the security measures they take in relation to the images.
- FMCI shall have in place appropriate and adequate procedures to ensure those guarantees are met including a right of access to the contractor’s premises or systems.
- the written contract makes it explicit that the third party can only use the images in accordance with the instructions of FMCI.
- the written contract makes the security guarantees provided by the third party explicit, including the length of time data is to be stored.
8. How do we secure personal data?
We are committed to ensuring data security, confidentiality and integrity. We seek to anonymise or pseudonymize personal data collected as part of our research, development and testing activities.
Our global Data Protection Compliance programme includes training, controls, policies, procedures and guidelines that help us develop and maintain cultural, organisational, physical and technical measures to ensure the security of your personal data.
This includes:
- The Data Processor Policy which imposes on data processors contractual terms consistent with the GDPR
- The Policy for International Transfer of Personal Data which requires FMCI employees to ensure that FMCI enters into EU Commission-approved international data transfer clauses which are mandatory where data is transferred outside of Europe
- Personal Data Breach Notification Procedure
- Non-disclosure agreements
- Mandatory training programs
- Tools and methods
Audits and controls
9. Your rights in relation to personal data
Where the collection of your personal data results from our CCTV system, signs are placed so that members of employees, clients and other stakeholders are aware that they are entering an area which is covered by a CCTV system, which allows them to access the relevant privacy notices issued by FMCI and to further understand the purpose of such data collection and how it is processed.
You have the following rights:
- The right to access the information we hold about you.
- The right to require us to rectify any inaccurate information about you without undue delay.
- The right to have us erase any information we hold about you in circumstances such as where it is no longer necessary for us to hold the information for your use of our services or if you have withdrawn your consent to the processing.
- The right to object to us processing information about you such as processing for profiling or direct marketing.
- The right to ask us to provide your information to you in a portable format or, where technically feasible, for us to port that information to another provider provided it does not result in a disclosure of information relating to other people.
- The right to request a restriction of the processing of your information.
- Where our processing of your information is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.
If you are unsatisfied with our use of your personal data or our response to any requests by you to exercise any of your rights, then you have the right to complain to the Data Protection Commission. See below contact details:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Email: [email protected]
Phone: +353 57 868 4800 / +353 761 104 800
10. How to contact us?
Should you have questions or concerns about data protection, your personal information, or should you wish to file a complaint, please contact FMCI’s Data Protection Officer whose details are:
Data Protection Officer,
Future Mobility Campus Ireland CLG,
Bay 80,
Shannon Free Zone,
Shannon,
Co. Clare,
Ireland
V14 WV82
Email: [email protected]
11. What will happen if we change our privacy notice?
This notice may change from time to time, and any changes will be posted on our website and will be effective when posted. Please review this notice each time you use our website or our services. This notice was last updated on the date appearing on the cover hereof.