Privacy Notice effective from 24th May 2018
Updated on 6th February 2019
This privacy notice tells you what to expect when companies within the Thomas Smith Group (namely, Thomas Smith & Co Ltd, TC Smith Agencies Ltd, TS Container Agencies Ltd, SGTS Logistics Ltd, SGTS Holdings Ltd, TCS Investments Ltd, Thomas Smith Insurance Agency Ltd and Thomas Smith Insurance Brokers Ltd), together ‘Thomas Smith’, ‘Us’ or ‘We’ collects personal information about you, in this case, static or moving imagery via CCTV or surveillance systems as you pass in front and through the Thomas Smith premises in Luqa as well as the bonded stores in Hal Far. Thomas Smith is committed to protecting your personal information, safety and security when you use Thomas Smith services. We are legally obliged to use your information in line with all applicable laws concerning the protection of personal data, including the General Data Protection Regulation (GDPR).
What information will we collect about you?
When you pass by or through the Thomas Smith premises or bonded stores, we may collect static or moving imagery via CCTV or surveillance systems.
How will Thomas Smith use the information it collects about me?
Thomas Smith may use CCTV or surveillance imagery for several purposes including but not limited to the following:
- To maintain the safety and security of the Thomas Smith staff and stakeholders
- For investigative purposes or as evidence to support any formal follow-up to Thomas Smith incidents
- In response to a Data Subject Access Request
The lawful justification for collecting and using CCTV or surveillance imagery is that there are legitimate interests to do so. CCTV and surveillance imagery may be handled and used by the following recipients to maintain a safe, secure and efficient operation:
- Thomas Smith personnel
- Police or Security services
- Other Thomas Smith service providers
We will keep your information within Thomas Smith and our trusted third parties except where disclosure is required by law, for example to government bodies, law enforcement agencies or in response to a Data Subject Access Request.
How long will Thomas Smith keep my information?
By way of general guidance, the supervisory authority advises a 7 day retention timeframe in connection with CCTV recording. Since operational activities within Thomas Smith premises and within the bonded stores area may be considered high risk due to monetary transactions and valuable goods handling respectively within daily business operations, CCTV recording may need to be accessed from 14 days prior.
Therefore, under normal circumstances your information could be retained for up to 14 calendar days after which point it will be deleted. Imagery required for investigative or evidential purposes may be retained beyond 14 days and is securely disposed of upon completion and conclusion of the purpose for which it has been retained.
Imagery is retained in a secure environment and is only accessible by authorised personnel who have a legitimate reason to do so.
What rights do I have over my personal data?
Under the General Data Protection Regulation, you will have the right to, where appropriate:
- Access your personal data by making a Data Subject Access Request
- Rectification, erasure or restriction of your information
- Object to the processing of your information
To exercise your rights please contact the Thomas Smith Data Protection Officer using the following contact details:
Data Protection Officer
1, War Victims Square,
Luqa LQA1010, Malta
Tel: (+356) 22058135
Or email: firstname.lastname@example.org
What if I find your response unsatisfactory?
Should you find our response unsatisfactory, you have the right to lodge a complaint with the supervisory authority – the office of the Information and Data Protection Commissionaire (IDPC).
You can find more information on the IDPC website at https://idpc.org.mt regarding the complaints process.
Changes to this privacy notice
We will keep this privacy notice under regular review and we will place any updates here. At the start of this privacy notice we will tell you when it was last updated.