MLL Telecom understands that your privacy is important to you and that you care about how your Personal Data is used. We will only collect and use Personal Data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
“CCTV” means Closed Circuit Television.
2. Information About Us
MLL Telecom Ltd registered in England under company number 02657917. Our registered address is Jubilee House, Third Avenue, Globe Park, Marlow SL7 1EY.
Our registration number with the Information Commissioner’s Office (ICO) is ZA325115.
3. What Does This Policy Cover?
This Policy provides details of why and how MLL will collect and process Personal Data. It applies to surveillance systems at our premises and in our vehicles. Personal Data will be contained within the video images of individuals recorded by dash cams on MLL vehicles and by the CCTV systems at MLL premises.
4. What Is Personal Data?
Personal Data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal Data is, in simpler terms, any information about you that enables you to be identified. Personal Data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are Your Rights?
You are entitled to know whether we hold Personal Data about you and, if we do, to have access to that Personal Data and request that it be corrected if it is inaccurate. You can also choose to manage the marketing communications you receive by using opt-out mechanisms in emails we send to you. In such cases, we will retain the minimum Personal Data necessary to record that you opted out, in order to avoid contacting you again.
If you are a Data Subject under applicable data protection law, you will have the following rights in relation to Personal Data that we hold about you:
- Right to Access – to request confirmation of whether we process Personal Data relating to you, and if so, to request a copy of that Personal Data;
- Right to Rectification – to request that we rectify or update any Personal Data that is inaccurate, incomplete or outdated;
- Right to Erasure – to request that we erase your Personal Data in certain circumstances, such as where we collected Personal Data on the basis of your consent and you withdraw your consent;
- Right to Restriction of Processing – to request that we restrict the use of your Personal Data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your Personal Data;
- Right to Withdraw Consent – where you have given us consent to process your Personal Data, to withdraw your consent; and
- Right to Data Portability – to request that we provide a copy of your Personal Data to you in a structured, commonly used and machine readable format in certain circumstances.
If you have any cause for complaint about our use of your Personal Data, you have the right to lodge a complaint with the ICO. We would welcome the opportunity to resolve your concerns ourselves.
Further information about your rights can also be obtained from the ICO, your local Citizens Advice Bureau or ourselves. If you wish to exercise any of your rights relating to your data (including requesting a copy of the Personal Data which we hold about you) please contact us in writing.
6. What Data Do We Collect?
Whilst operating our services and vehicles, we may collect the following personal information:
- Video images of you.
- Your vehicle details (for example, vehicle licence plate number and vehicle type).
7. Why We Can Collect and Use Your Personal Data?
MLL capture, record and monitor record images for the safety and security of persons, property & premises, the prevention & detection of crime and to learn lessons from incidents which can be incorporated into driver awareness training. Therefore the processing is necessary for the purposes of our legitimate interests or a third party.
We use your personal information to:
- Increase the security and welfare of employees when there are concerns around their safety.
- To prevent, deter, and if necessary, investigate unauthorised physical access, including unauthorized access to secure areas or information.
- To prevent, detect and investigate a theft of equipment or assets owned by MLL, visitors or staff or threats to the safety of personnel working at the office (e.g. fire, physical assault).
- Provide data intelligence for insurance claims, incidents and accidents.
- Assist with the prevention and detection of theft, vandalism and to protect property.
- Train staff.
The location and positioning of the video-cameras are such that they are not intended to cover the surrounding public or private spaces; the cameras are aimed to give a general overview of activity in certain places to ensure the security of the premises and staff. The CCTV system generally covers entry & exit points and secure areas within the MLL premises.
Dashcam footage will be collected by the activation of the vehicle ignition or when the motion sensor is activated on the vehicle. It has a built-in collision sensor which locked recording. The output video shows date/time and location.
MLL are the Data Controller of the recorded images from our surveillance systems. We will only use your Personal Data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your Personal Data for that purpose.
8. How Long Will We Keep Your Personal Data?
MLL has a Data Retention Policy which mandates how long records, including Personal Data, must be retained. Retention periods are determined by legislation and business requirements. In most cases we will hold your data for a minimum of 31 days. After that period any recorded footage is automatically overridden, unless required for the purposes of an official investigation.
We will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected.
9. How We Store and Keep Your Personal Data Secure?
We have appropriate security measures in place to prevent personal information from being accidently lost or used or accessing in an unauthorised way. The security of your Personal Data is essential to us, and to protect your data, we take a number of important measures, including the following:
- Limiting access to your Personal Data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
- Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Personal Data) including notifying you and/or the Information Commissioner’s Office where we legally required to do so.
The data in the system will be automatically recorded and will not be tampered with. The data is stored in the in the UK.
Viewing and analysis of the CCTV images will only be undertaken by authorised employees. Recordings are kept in a secure, access controlled location.
10. Do We Share Your Personal Data?
We will in some circumstances have to share your data with third-party service providers that perform services on our behalf. We will not share any of your Personal Data with any third parties for any purposes, subject to the following exceptions:
- In some limited circumstances, we may be legally required to share certain Personal Data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How You Can Access Your Personal Data?
If you want to know what Personal Data we have about you, you can ask us for details and for a copy of it (where any such Personal Data is held). This is known as a “subject access request” and should be made in writing and sent to the email or postal addresses shown below.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your Personal Data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
12. How Do You Contact Us?
To contact us about anything to do with your Personal Data and data protection, including to make a subject access request, please use the following details:
- Data Protection Officer: Mark Gibbons.
- Email address: email@example.com.
- Telephone number: 01628 495400.
- Postal Address: MLL Telecom, Jubilee House, Third Avenue, Globe Park, Marlow SL7 1EY.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects Personal Data protection.
Any changes will be immediately posted on our website. We recommend that you check this page regularly to keep up-to-date.