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Last updated: March 2022
This privacy notice tells you what to expect when Heathrow Airport Ltd (Heathrow) collects personal information about you, in this case, static or moving imagery, audio and meta data such as vehicle plate data via the surveillance systems as you pass through the airport. Heathrow is committed to protecting your personal information, safety and security when you use Heathrow services. We are legally obliged to use your information in line with all applicable laws concerning the protection of personal data, including the UK General Data Protection Regulation (UK GDPR).
When you use Heathrow Airport we may collect, static or moving imagery, audio and meta data such as vehicle plate data, via the surveillance systems using both static and mobile devices, such as staff activated body worn cameras. Heathrow collects this data via surveillance devices located throughout the airport, in both landside (public) and airside (restricted access) locations.
Heathrow may use surveillance data for a number of purposes including but not limited to the following:
The lawful justification for collecting and using surveillance data is that there are legitimate interests to do so. Surveillance data may be handled and used by the following recipients to maintain a safe, secure efficient and compliant airport operation:
Some of Heathrow's surveillance camera infrastructure is shared with third parties such as the Police, UK Border Force, local authorities and some service partners. They may take control of cameras and use them for security or crime prevention activities, for example. These arrangements are covered by information sharing agreements and Heathrow is not responsible for the cameras when in the control of the third party.
We will not transfer or disclose your personal information, other than: as identified in this Privacy Notice, to our trusted third-party suppliers and/or to the police, tribunals, courts, regulators, or other authorities to assist them with their investigations or requests and/or for us to report security incidents or suspected or actual unlawful acts and/or as may be otherwise required by law or in response to a subject access request. Your information may very occasionally be processed outside of the UK for the purposes of system maintenance and support or for the purposes of international security and crime prevention.
Heathrow colleagues and our representatives may in limited circumstances use BWC. Our colleagues will inform you if you are being filmed unless the situation means we are unable to communicate this with you. While we do not rely on consent, the footage is handled by authorised Heathrow colleagues in line with the rest of this privacy notice.
BWC have a 60 second record function, which is continuously overwritten unless the device is switched on to save footage or the device senses an impact. The record function will be manually turned off by the operator. BWC will only be recording when the situation requires it for example for health and safety or for investigations etc. Footage and audio that is recorded will be saved onto Heathrow systems and will be kept for 31 days unless it is needed for investigative or evidential purposes.
Under normal circumstances, your information could be retained for up to 31 calendar days after which point it will be deleted. Imagery required for investigative or evidential purposes may be retained beyond 31 days and is securely disposed of upon completion/conclusion of the purpose for which it has been retained. In certain circumstances, for example, the capture of Automatic Number Plate Recognition, images could be kept for up to 90 days.
Imagery is retained in a secure environment and is only accessible by authorised personnel who have a legitimate reason to do so.
Under the UK General Data Protection Regulation, you will have the right to, where appropriate:
To exercise your rights please contact the Heathrow Data Protection Officer using the following contact details:
Data Protectiion Officer
Heathrow Airport Ltd
The Compass Centre
Or email: email@example.com
A new era has begun for the UK and EU now that the Brexit transition period is over. From time to time we may process personal data from EU residents. Whenever applicable, we have appointed an EU Representative to ensure that we continuously process your personal data in compliance with applicable laws and without undermining your statutory rights.
You can contact our EU Representative at HeathrowEURepresentative@eversheds-sutherland.com and write EU Representative as subject matter. You may also contact our EU Representative per post mail at:
Eversheds Sutherland Netherlands B.V.
Attn. EU Representative Heathrow Airport
Fascinatio Boulevard 212
3065 WB Rotterdam
Should you find our response unsatisfactory, you have the right to lodge a complaint with the supervisory authority – the Information Commissioner’s Office (ICO). You can find more information on the ICO website at https://ico.org.uk/concerns/ regarding the complaints process.
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.
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