VMC4 Non-Connected Privacy Notice

1. Overview
2. Who is responsible for your personal data
3. What personal data do we collect about you
4. Why do we collect this personal data
5. How do we process your personal data
6. Where do we process your personal data
7. How long do we keep your personal data
8. Sharing personal data to others
9. Protecting your personal data
10. Your data protection rights
11. Updates to this policy
12. Contact information
13. Making a complaint
14. Document Version

 

1. Overview

This Vehicle CCTV & Telematics Privacy Notice applies to anyone that enters vehicle(s) belonging to SEE VEHICLE STICKER either as a driver or a passenger; this can include customers, employees and members of the public; and also any individual that comes into proximity of our vehicles.

CCTV images are being monitored and recorded around our vehicles for crime prevention, crime detection and for the safety of our customers, employees and the public.

All cameras are carefully positioned not to be intrusive on vehicle occupants and no internal facing cameras are installed, nor does the system record audio.

Our vehicles display signage informing all users of our vehicle of the use of CCTV and Telematics. We, the Data Controller, provide all vehicle users with our Vehicle CCTV & Telematics Privacy Notice and make it publicly available on this website providing all users with detailed information about how your personal data is processed.

The scheme is controlled by SEE VEHICLE STICKER and/or Section 2 of this Privacy Notice.

 

2. Who is responsible for your personal data

The details of who is responsible for your personal data along with contact information can be found on the VEHICLE STICKER which is located in various location on the vehicle. Hereafter referred to as the ‘Data Controller’.

The Data Controller controls the ways and reasons your personal data is collected and also the purposes for which we, the Data Controller, collect, use and retain your data and we are therefore the “Data Controller” for the purposes of data protection laws including the European General Data Protection Regulation (GDPR) and Data Protection Act 2018.

 

3. What personal data do we collect about you

We, the Data Controller, collect CCTV footage on all of our vehicles, this may capture your movements and activities whilst using or travelling in our vehicles which may reveal facial images of individuals, location information, and activities around our vehicles.Customers and users of other services provided by the Data Controller may have more personal data collected; details of which can be obtained by contacting the Data Controller.

 

4. Why do we collect this personal data

We, the Data Controller, monitor and record CCTV in our vehicles for the purposes of crime prevention, crime detection and for the safety of individuals which may include our customers, employees and members of the public.

 

5. How do we process your personal data

Vehicle CCTV images and Telematics data are actively recorded and monitored by the Data Controller (and if applicable their employees) for the purposes of crime prevention, crime detection and for the safety of individuals which may include our customers, employees and members of the public.

 

6. Where do we process your personal data

All CCTV footage and Telematics data (including backups) are kept by the Data Controller are stored fully within the EEA at all times in accordance with data protection laws. Backups may be taken as defined in Section 7 this and stored within the following location:

  • Data Controller’s Internal Network where backups are taken this information is stored within the Data Controller’s network infrastructure. This is stored in the EEA.

 

7. How long do we keep your personal data

All vehicle CCTV recordings are retained for a period of approximately 35 vehicle operating hours, and automatically deleted thereafter if there is no indication of an actual or potential crime, or an incident that may result in a claim being made either against us by a third party or by us against a third party.In cases where the CCTV footage shows an actual or potential crime, or an incident that may result in a claim being made either against us by a third party or by us against a third party then the CCTV footage will be retained by us for the duration of the proceedings plus the mandatory legal retention period thereafter that we, the Data Controller, must keep the data. This can vary depending on the nature of the crime / claim.

 

8. Sharing personal data to others

Our CCTV and Telematics system is actively monitored by the Data Controller (and if applicable their employees). The Data Controller does not typically share vehicle CCTV footage and Telematics information with any other parties, however your personal data may be shared with other organisations where it is required to do so in order to fulfil the purposes of crime prevention, crime detection and for the safety of our customers, employees and the public.The Data Controller therefore may also share CCTV footage & Telematics with the following organisations only where required:

  • Our CCTV & Telematics provider (Vision Unique Equipment Limited) where we, the Data Controller, are required to do for customer support and assistance with the camera systems and/or retrieving information from the devices.
  • The Police where we, the Data Controller, are required to do so to comply with legal obligations such as if a crime has or potentially has been committed and the CCTV footage and/or Telematics data can assist Police with their investigations.
  • Our insurance providers where a claim is made either against us by a third party or by us against a third party or our insurer to which the CCTV footage and/or Telematics data can be used as evidence for the claim being made.
  • Our legal advisors where a claim is made either against us by a third party or by us against a third party to which the CCTV footage and/or Telematics data can be used as evidence for the claim being made.
  • Our appointed Health & Safety consultants who act as our HSE competent person where an injury or potential injury has occurred in or near our vehicles.
  • Other businesses only in the instance where a crime has been committed or a claim has been made to which the CCTV footage from our vehicles can be used as evidence for the claim being made.
  • Members of the public who submit a Subject Access Request where there is no overriding legal basis not to provide the information (please note depending on the nature of the request other parties captured in the footage may be pixelated to ensure their privacy).

 

9. Protecting your personal data

We, the Data Controller, are committed to protecting all personal data we process and take appropriate technical and organisational measures against the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your personal data, transmitted.We, the Data Controller, fully comply with our obligations as a “data controller” under all data protection laws including the European General Data Protection Regulation (GDPR) and Data Protection Act 2018.

 

10. Your data protection rights

The European General Data Protection Regulation (GDPR) gives individuals “data subjects” specific rights that help you control your personal data. Below you will find more information about your rights and how we work to fulfil these in regards to our CCTV monitoring and processing. You can exercise any of your rights in relation to the data in this policy,that we the Data Controller, holds about you by contacting us; details of where our contact information can be found are in the Contact Information section of this policy.

  • Right to be informed: You have the right to be informed when your personal information is being collected and how it will be processed. We, the Data Controller, therefore ensure our vehicles display signage informing all users of our vehicle of the use of CCTV and Telematics with a link to this Vehicle CCTV & Telematics Privacy Notice providing all individuals with information about how your personal data is processed.
  • Right to access: You have a right to request for copies of CCTV images or recordings we, the Data Controller, have that feature images of you or information relating to you. We, the Data Controller, allow you to submit a Subject Access Request (SAR) to obtain your personal information, this is done by contacting us; details of where our contact information can be found are in the Contact Information section of this policy.

In order to fulfil any Subject Access Request, so you can receive a copy of the CCTV we, the Data Controller, hold we may need more information about you and the footage you require including (but not limited to): Date, Time, Location, Your description, and contact details; this information should also be provided when submitting any Subject Access Request.

  • Right to rectification: You have the right to request the information held is rectified if it is found to be inaccurate or incomplete. All requests of data rectification can be made by contacting us; details of where our contact information can be found are in the Contact Information section of this policy.
  • Right to erasure: You have the right to request we, the Data Controller, stop processing your data and for the information we hold to be erased in certain circumstances such as if your data is being unlawfully processed. All requests of data erasure can be made by contacting us; details of where our contact information can be found are in the Contact Information section of this policy.
  • Right to restriction:You have the right to request we, the Data Controller, stop or limit how we process your data but not delete your information in certain circumstances such as if your data is being unlawfully processed. All requests of data erasure can be made by contacting us; details of where our contact information can be found are in the Contact Information section of this policy.
  • Right to portability:You have the right to request your data is sent to you and/or another data controller in a common machine-readable format. If you require us to send your information to another data controller this can be done by contacting us; details of where our contact information can be found are in the Contact Information section of this policy.
  • Right to be objection:You have the right to object to the processing of your data until we, the Data Controller, can demonstrate compelling legitimate grounds for doing so. All objection requests can be made by contacting us; details of where our contact information can be found are in the Contact Information section of this policy.
  • Automation rights: You have the right not to be subject to automated profiling or predictive measures and request human intervention and an explanation of automated decisions. All requests relating to automation rights can be made by contacting us; details of where our contact information can be found are in the  Contact Information  section of this policy.

 

11. Updates to this policy

This Vehicle CCTV & Telematics Privacy Notice is a dynamic tool and changes to this policy may be required to reflect any changes in the way personal data is processed by the recording unit. This information may therefore be updated to ensure the information provided to you is up to date and in accordance with the relevant data protection laws. Any new version of this policy will be republished on this website.

 

12. Contact information

We, the Data Controller, will always try to resolve queries and respond appropriately to all requests and enquiries regarding the use of our CCTV & Telematics data. You can contact the Data Controller using the contact information can be found on the VEHICLE STICKER which is located in various location on the vehicle. Please Note: VUE are not the Data Controllers of these systems and may not have nor be able to provide details of any Data Controllers.

 

13. Making a complaint

You have the right to make a complaint to the Information Commissioner’s Office if you have concerns about our practices, or you are not happy with our responses to your requests or you are concerned about how we are handling your information.The ICO can be contacted through this link: https://ico.org.uk/concerns/

 

14. Document Version

Version 1.1 - Last updated 20/03/2020

This Privacy Notice was produced to assist owners of our systems to meet their obligations under data protection laws and provide the details of the standard processing activities for our systems. Where system owners also known as “Data Controllers” or other parties intend to process data differently to that stated in this Privacy Notice, the data controller is instructed to produce their own Privacy Notice and vehicle stickers and to make those available to individuals instead.

VUE cannot and therefore does not accept any responsibility for the accuracy of this information and all responsibility falls onto the Data Controller.