Thermal Imaging Camera Privacy Notice
Purpose of this notice and information about the controller
As part of our COVID-19 return to work project, Walker Morris LLP (Walker Morris, we, us) are utilising a thermal imaging camera (the Camera) to identify any individuals with an elevated body temperature (EBT). The Camera will be installed Walker Morris’ Office at 33 Wellington Street, LS1 4DL (the Premises). Individuals who are identified as having an EBT will be asked to leave the Premises.
The purpose of the camera is to reduce the likelihood of an individual who has COVID-19 symptoms from entering the Premises and infecting others with the virus. The Camera will process the personal data of any employees, visitors and third parties (collectively referred to as data subjects) that pass by the Camera.
The purpose of this notice is to explain how Walker Morris will process your personal data in association with its use of the Camera in accordance with Regulation (EU) 2016/679 the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA).
For the purposes of the Camera, Walker Morris will be the data controller. This means that Walker Morris will be the entity that decides how and why the Camera will be used to process your personal data.
Walker Morris is registered with the Information Commissioner’s Office as a data controller and has the registration number Z3377061. Jeanette Burgess is Walker Morris’ Data Protection Officer. Questions about this privacy notice can be sent to Jeanette at email@example.com or firstname.lastname@example.org.
How the Camera works
The Camera will be set up facing the entrance to the lift lobby, which will be the only entrance in use to access floors above the ground floor until the coronavirus prevention methods are lifted or revised. As data subjects arrive at the office, they will pass in front of the Camera one at a time.
A laptop will be connected to the Camera and will be facing data subjects. The laptop will show real-time images of the Camera’s view. The Camera will not record video and so these images will not be captured or stored. In addition to capturing ordinary images, the Camera also has the functionality to recognise when a face is within its view. The Camera is only able to identify whether or not a face is in view, it cannot ‘recognise’ individual faces and does not record any facial recognition data that can be used to identify individual people (known as biometric data).
Where a face is within view, the Camera automatically monitors the body temperature of the face and this is shown in real time on the laptop screen. The Camera has been programmed with the ordinary range of body temperatures and can therefore recognise when a data subject with an EBT passes within its view.
Where a data subject with an EBT passes in front of the camera, a warning is sounded and two images are taken at the same time. One image shows the Camera’s normal view (like a photograph) and the other is a thermal image which shows the EBT that has been recorded for the data subject.
While the images are taken, the laptop continues to show the live footage and the images are not otherwise displayed on screen for anybody to see.
The images taken by the Camera can be viewed in order to confirm the relevant temperature reading if necessary. They are retained for no more than 24 hours and then they are permanently deleted from the laptop.
What personal data is processed and why
The Camera processes images of data subjects. The Camera will also process data subjects’ temperature which is a special category of personal data under the GDPR and the DPA.
The above personal data is processed in order to ensure that data subjects who have an abnormally high body temperature are not permitted to access the premises. An EBT is a potential sign of coronavirus. Failure to provide personal data (by refusing to walk in front of the camera for example) will mean that you may not access the Premises.
While not all data subjects that have an EBT will be suffering from the coronavirus, and some people may have the coronavirus without suffering from an EBT, the Camera is one of many measures that is being implemented by Walker Morris to ensure the health and safety of its staff and visitors.
Our legal basis for processing this personal data (and our additional legal basis for processing the special category data) is as follows:
Article 6(1)(c) GDPR – processing is necessary for Walker Morris to comply with its legal obligations to provide a safe working environment and ensure the health and safety of visitors to its premises;
Article 9(2)(b) – processing is necessary for Walker Morris to carry out its obligations in the field of employment, social security and social protection law. The thermal imaging camera is one of several reasonable and proportionate measures that are being implemented in order to meet this obligation.
Storage, transfer and retention of your personal data.
The personal data will only be stored on the laptop that is connected to the camera. This laptop is not connected to any network and the personal data cannot therefore be accessed other than by using the laptop. Only a limited number of designated staff members are authorised to access the personal data on the laptop.
The personal data will never be transferred to any third parties and will be deleted in all cases within 24 hours of being collected.
All of your ordinary data subject rights apply to the personal data processed by the Camera. For more information about these rights, please see our standard privacy notice at https://www.walkermorris.co.uk/privacy-and-cookies-notice/.
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Last updated: 26 June 2020