CCTV and Body-Worn Cameras: Privacy Notice
This privacy notice explains how we collect and use personal information about you for the following process: Recording and storing of CCTV footage, ANPR and Body-Worn video (BWV) footage across the Essar Group sites.
What is the purpose of this document?
We place great value on honesty and integrity. We are committed to protecting, safeguarding, and respecting your privacy.
This privacy notice references “we”, “us” and “our” which means Essar Oil UK Limited (trading as “EET Fuels”) and its group of subsidiary companies (referred to as the “group” below).
This privacy notice describes how we collect and use personal information about you for the following process: Recording and storing of CCTV footage, ANPR and BWV across the Essar group sites.
We are the data "controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
We may update this notice at any time.
About the use of CCTV and Body Worn Videos
We use closed-circuit TV (CCTV) and, where necessary, body-worn video (BWV):
CCTV camera locations are chosen to minimise the capture of images which are not relevant to the legitimate purposes of the monitoring.
The term CCTV takes the same meaning as surveillance camera system as defined in s29(6) Protection of Freedoms Act 2012 and includes use of:
Who does it apply to and the source of the information?
This privacy notice applies to individuals who visit our sites and their personal data is captured when they come into range of either internal and external cameras or security officers wearing BWV.
Data Protection Principles
We will comply with data protection law, which says that the personal information we hold about you must be:
We as the controller shall be responsible for and be able to demonstrate compliance with the Data protection Principles.
Type of information we hold and process about you
The personal data we collect from you through the use of CCTV will include:
The personal data we collect from you through the use of activated BWV will include:
The personal data we collect from you through the use of ANPR will include:
Where images or recordings show evidence of an offence, it may be combined with other personal data we hold about you. That data may include:
Why do we process your personal data
We will process personal data for these purposes:
Where CCTV footage or BWV incidentally captures an accident within the site, we may need to consider it and share it internally and with the Health and Safety Executive (HSE) and our insurer for the purposes of assessing and if necessary, defending any claim.
The main purpose of the processing is listed above, however, if an allegation of misconduct is made against a staff member, CCTV images or BWV footage may be used in the investigation to provide a true and fair assessment of events.
The legal basis for our processing
Our legal basis for processing your personal data is:
Our basis for processing special category persona data is:
Who we will share the personal data with
Personal data may be shared with specific departments or individuals within the Group where there is justification, or where it is necessary to protect the health, safety and welfare of employees and other people under the Health and Safety at Work etc act 1974. The purpose of sharing is to make it safe for those who work or visit our sites and to effectively identify and control risk of injury or health that could arise.
Where there is a claim as a result of an accident CCTV footage of the accident containing personal data may be shared with specific departments or individuals within the group where there is justification (e.g., with Facilities Management, Resilience (risk and insurance), Legal Services, Human Resources. It may also be shared externally with the HSE and with third-party insurance companies.
We will share your data to a competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Essar company/companies is subject or as permitted by applicable law – for example, by court order or to prevent fraud or other crime.
The process for sharing personal data will be consistent with the guiding principles and statutory requirements of the UK GDPR and the DPA.
Retention of data
The retention period for personal data processed by the CCTV system reflects the purpose for which it was collected, and it will not be kept for longer than is necessary to achieve this purpose.
Personal data recorded on CCTV cameras will be held on our secure servers for a period of 28 days whereupon it is then automatically deleted.
BWV footage is downloaded after every incident and data deleted from the device. Any incident footage that is non-evidential material is retained for a maximum of 31 days. All incident footage is deleted on conclusion of the investigation.
Where any accident relates to a health and safety incident the data will be retained as per the HSSE statutory legislation for retention.
Your rights in relation to your personal data
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
The right to object to the processing of personal data for the purposes of a public interest task is restricted if there are legitimate grounds for the processing which override the interest of the data subject.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
The right of erasure and the right to object to processing of personal data do not apply where personal data is processed for the performance of a legal obligation. This will be considered on a case-by-case basis and depends on what personal data is involved and the risks further processing of that data could pose to you.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing.
Please contact DPO@eetfuels.com
Data Protection Officer ( DPO )
We have appointed a DPO to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You can do this by email via DPO@eetfuels.com or in writing to Essar Oil (UK) Limited, 5th Floor, The Administration Building, Stanlow Manufacturing Complex, Ellesmere Port, Cheshire, CH65 4HB United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) with respect to data protection issues.
Contact details
Information Commissioner's Office
Wycliffe House Water Lane
Wilmslow Cheshire United Kingdom
SK9 5AF Website: www.ico.org.uk Phone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
This privacy notice was last updated in November 2024.
If you have any questions about this privacy notice, please contact the DPO by sending an email to DPO@eetfuels.com
