WE Soda: CCTV Privacy Notice

WHO WE ARE

WE Soda Ltd (‘WE Soda’, ‘we’ or ‘us’ or ‘our’) is a company registered in England and Wales under company number 10264457. Our registered office is at 23 College Hill, London EC4R 2RP.

YOUR PRIVACY

Introduction

This privacy notice explains how WE Soda uses your data when captured on CCTV.

WE Soda has CCTV in operation at WE Soda London office building at all floors. CCTV will capture images in real time wherever the cameras are pointed. These cameras may capture footage of you whilst you are on the premises. Cameras are situated both inside and outside the buildings. There are signs in place to inform you where cameras are in use. 

Who will be using your data?

WE Soda will be the data controller for the data you provide to us. 

What personal data do we use?

Static and moving images of people.

What types of special category personal data do we need from you?  

We do not deliberately set out to capture any special category personal data. However, cameras may incidentally record information which falls within these categories. Additionally, footage recorded by the cameras may be used as evidence regarding criminal offences or related security measures. 

Why do we use your data? 

To ensure the security of employees, service users and visitors to the sites.

What legal reasons allow us to use your data in this way? 

Our basis for processing personal data is: 

  • there is a substantial and legitimate interest in processing this information, for the purposes of ensuring the security at WE Soda UK office.

Who may we share your data with?

Sometimes we need to share your information with others, as described below:

  • We may be asked to provide footage to assist the police with any criminal damage or their investigations.

  • We may use the footage to assist the internal investigation if there is any incident or whistleblowing report with the approval of Chief Legal Officer.

  • Third-party service provider for the CCTV system may have access to recordings stored on the internal network storage location for our company, as part of their services such as maintenance, calibration, integrity checks and troubleshooting the CCTV system etc.  

We will only do this when it is necessary, or if we are required to do so by law. We do not plan to share it with anyone else or use it for anything else. However, there is no planned regular or scheduled sharing of CCTV footage with any external organisation or internally. Should this situation change, this privacy notice will be updated and reissued.

CCTV footage will only be processed internally by Data Controller who is authorised to do so and any other departments where there is a legitimate and lawful reason for their involvement, such as HR or Compliance colleagues in the event of an investigation. 

How long is your data kept for? 

All camera recordings are retained for a maximum of four (4) weeks from the date of recording. After this period, recordings are automatically deleted, unless they are kept for the purposes of ongoing investigations. In such a case the recordings will be retained only for the duration that is necessary to complete any investigation or legal process.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data, as follows:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

If you wish to contact us about any of these rights, see our contact details below. 

CHANGES TO THIS CCTV PRIVACY NOTICE

This privacy notice may be updated from time to time, and you are requested to periodically return to this notice to familiarise yourself with any changes.

CONTACT DETAILS 

If you have any questions about this privacy notice or our privacy practices, please contact us at [email protected].

Please contact us if you are unhappy about our processing of your personal data. You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We are registered with the Information Commissioner’s Office under number ZA844354 as the data controller responsible for processing your personal data.

This privacy notice is effective as of 30 November 2023.


© 2023 WE Soda Ltd, 23 College Hill, London EC4R 2RP. All Rights Reserved. Company No: 10264457 Registered in England & Wales