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Video surveillance systems privacy notice

If your personal information has been captured using our video surveillance systems, including through the use of CCTV cameras and digital doorbells, this Video surveillance systems privacy notice will help you understand the types of personal information we collect, why we need to process your personal information, how we use it, who we share it with, and the rights you have over it.

This notice also covers the personal information we may process on behalf of one or more of our clients, using drone technology (for example, unmanned aerial vehicles, ‘UAVs’). Where we (or a third-party service provider) use drones to process your personal information, we will only process your information as instructed by our client and in accordance with the written agreement between us and that client. Please refer to the ‘Drone technology’ section of this policy for further information.

In certain locations, there may be differences in the way that we collect and use personal information due to local legal requirements or the way that Mott MacDonald operates. If that is the case, we will notify you of this in a supplementary privacy notice.

This privacy notice is aligned with both our Privacy and data protection policy and Our Code.

How we use your personal information

Generally, we collect your personal information when you visit our offices or other premises where we provide our services. We capture personal information through the use of video surveillance systems for the following purposes:

Safety and security

  • Personal safety of our People and visitors including clients, job applicants, contractors, external training providers, supplier/vendor contacts, work experience apprentices and trainees and other members of the public
  • Protection of our premises and assets from damage, disruption, and vandalism
  • Crime prevention and detection

Internal management and investigation

  • Supporting internal investigations
  • Assist in effective resolution of disputes which arise in the course of disciplinary or grievance proceedings

Compliance with legal obligations

Disclosing personal information to government institutions or regulatory authorities as applicable in all countries in which Mott MacDonald operates, such as record-keeping and reporting obligations, compliance with government inspections and other requests from government or other public authorities, responding to legal processes such as subpoenas, pursuing legal rights and remedies, and managing any complaints or claims.

Responding to any legal claims

Establishing, exercising, or defending our legal position.

Personal information we may need to process

Below is a list of the categories of personal information that we may collect, use, and store for our own purposes:

  • Identification information: Vehicle license plate
  • Images: CCTV and video footage
  • Biometric data: Facial features and video footage

For the purposes of this notice, children’s personal information (those under the age of 16) is not routinely captured by us and we do not normally expect children to enter our offices or premises where we provide our services. However, in rare circumstances, very limited personal information may be collected (for example, in the event children accompany parents on their visit to our offices) such as capturing their image on our video surveillance systems (CCTV) for the purposes of securing our premises.

How we collect your personal information

We collect your personal information when you visit our offices or other premises where we provide our services. This will normally be through the use of video surveillance technology, including CCTV cameras, digital doorbells, and door entry facial recognition software. Video surveillance equipment, hardware and software support are provided by a third-party vendor (for example, ADT Security Services in the United States). Video surveillance technologies are clearly visible and are not hidden from sight, nor are they made to appear as non-surveillance equipment. Surveillance equipment are strategically placed to capture entry to our offices or premises where we operate, freight elevators, security server rooms, and parking areas. Where possible, signs are displayed to inform employees and visitors that video surveillance systems are in operation and who to contact for further information. Cameras are in operation 24 hours a day, 7 days a week.

At certain office locations, video surveillance technology will be managed and operated by the building administrator. We do not control, operate, or normally have access to these recordings. You should direct your privacy enquiries, including any requests to exercise your privacy and data protection rights, to the building administrator.

How we justify our use of your personal information

We will only use personal information about you when the law allows us to do so. We normally rely on one or more of the following legal justifications when we collect, use, handle, or share your personal information:

  • as necessary to fulfil and perform any contractual obligations that we have entered into with you.
  • as necessary to comply with a legal obligation.
  • as consistent with your consent to processing of your personal information.
  • as necessary for our legitimate interests and business needs.
  • as necessary to protect your interests or someone else’s interests.
  • as necessary in the public interest.

Some of the above justifications will overlap, so it is possible that more than one legal justification will apply at the same time to enable us to process a particular element of your personal information.

In certain locations, there may be differences in the legal justifications that can be relied upon when we collect, use, and handle personal information due to local legal requirements or the way that Mott MacDonald operates in that territory. If that is the case, we will notify you of the differences in a supplementary privacy notice.

Who we may need to share your personal information with

Where we process your personal information for our own purposes, we will share your personal information with third parties only when it is necessary and proportionate to do so. We may share personal information with:

  • External service providers who supply us with our video surveillance equipment, systems, and software for technical support.
  • Regulatory authorities as required by law.
  • Law enforcement agencies investigating alleged criminal offences by individuals or organisations.

When we need to share your personal information with third parties, we use a combination of contractual, physical, and technical measures to keep it secure. Please refer to our Group policies for more information.

Please note that we will never sell your personal information to another organisation for any purpose.

Processing your personal information in (or from) other countries

We are a global business, and our clients and trusted business partners, including service providers and suppliers, are located all over the world. This means that your personal information may need to be accessed, stored, used, handled, or otherwise processed in countries outside the one where you are normally located, for the purposes described in this notice.

Before sharing your personal information across international borders, we ensure that appropriate safeguards are in place and that your privacy and data protection rights are protected. Those safeguards will normally include data encryption, role-based access permissions, and legal agreements that facilitate the lawful cross-border transfer of personal information.

How we protect your personal information

We work hard to maintain and improve security measures that prevent personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Access to recorded footage is limited to individuals or organisations who have a legal right of access (for example, regulatory authorities or law enforcement agencies) or a legitimate business need to know (for example, authorised members of our workforce whose role requires them to have access to such data and are subject to contractual obligations of confidentiality). We ensure that video hard drives are located in a secure server room and video recordings can only be accessed with the correct access control privilege. Password protection and technical access controls are also protection measures that we use.

Our service providers will only process personal information under our instructions, and we ensure that all third parties are subject to a legal duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any relevant regulatory authority of a breach when required.

All Mott MacDonald People, including employees involved in the management and operation of our video surveillance systems, are required to complete mandatory privacy and data protection training on an annual basis.

Please also see our Information security and Privacy and data protection Group policies for more information.

How long we keep your personal information

Mott MacDonald will only keep personal information which permits identification of individuals for no longer than is necessary for the purposes set out in this notice. Video surveillance recordings are generally kept between 30 and 60 days from the date of the recordings and are permanently deleted after that time. We may keep recordings for longer when required, such as in cases of ongoing investigations of theft, crime, or accident or when required by law.

When your personal information is deleted or destroyed, we ensure that it is safely and permanently disposed of in accordance with any local legal requirements.

Your rights over your personal information

Where we process your personal information for our own purposes, Mott MacDonald gives you control over your personal information. To ensure the security of personal information and prevent fraudulent requests, we may need to collect personal information including your name and contact details to verify your identity. Please ensure you describe your request with sufficient detail to allow us to properly evaluate and respond to it. As a visitor to any of our offices or premises where we provide our services, you have the following rights over your personal information:

  • Right of access to your personal information. This enables you to request a copy of your personal information and to check that we are processing it lawfully.
  • Right to correct the personal information that we hold about you. This enables you to ask us to amend or update any incomplete or inaccurate personal information.
  • Right to request erasure of personal information about you. This enables you to ask us to delete or remove personal information where there is no valid reason for us to continue processing it.
  • Right to object to the use of your personal information if you think we do not have a valid reason to process it and want us to stop processing it.
  • Right to restrict further use of personal information about you. This enables you to ask us to limit or suspend the use of your personal information (for example, if you want us to confirm its accuracy or the reason why we are processing it).
  • Right to transfer personal information about you to another party. You can ask us to send (or “port”) your personal information to another organisation.

We respect your rights over your personal information. You can exercise those rights at any time by initiating a request using our online individual rights request form. If you choose to exercise your rights, we are committed to treating you fairly and to ensuring non-discriminatory treatment.

Drone technology

We use drone technology (UAVs) in very limited circumstances and only on behalf of and as instructed by our clients. Generally, we use drone technology (as part of client projects) for the purposes of environmental surveys, infrastructure inspections, and land surveying.

We ensure that appropriate licensing approvals and certifications have been obtained by our workforce or any third-party operating drone technology on our behalf. We conduct assurance reviews to ensure that licensing certifications are up-to-date and that any safety parameters set by regulatory authorities are adhered to. Our service providers will only process personal information under our instructions, and we ensure that all third parties are subject to a legal duty of confidentiality.

Please note that we generally do not collect personal information when using drone technology for client projects and use appropriate measures to restrict and avoid capturing images and video footage of individuals and private residences. Where a client project involves capturing aerial images over private residences, we ensure that appropriate licensing requirements and contractual agreements are in place to do so, and individuals have been provided with adequate notice (either provided directly by our client or provided by us on behalf of our client).

Below is a non-exhaustive overview of the categories of personal information that we may process on behalf of one or more of our clients. This information will depend upon each client’s need and the purpose of their specific project. You should direct your privacy enquiries, including any requests to exercise your privacy and data protection rights, to our client directly. We will delete your personal information in line with their instruction.

  • Images: Video footage, photographs
  • Location data: Geographic descriptor (eg street name), GPS coordinates (eg for client environmental surveys)
  • Biometric data: Video footage, photographs

We will only share your personal information with our client and any third parties that the client authorises. Please note that we are not responsible for the privacy or information security practices of our clients, which may differ from our information security practices.

Contact us

If you have any concerns about this privacy notice, or how we have used your personal information for our own purposes, please contact our Privacy and Data Protection Team at privacy@mottmac.com. If you’re located in Singapore, you can also contact us by calling 6293 1900. If you’re a resident of California, please contact privacyamericas@mottmac.com or dial 800.832.3272.

If you have questions about our processing of your personal information on behalf of a client, please contact them directly. If you’re unhappy with how we have used your personal information, you can register a complaint with the data protection regulator in the country, state, or province where you are located.

Changes to our video surveillance systems privacy notice

This privacy notice was issued in January 2023 and may need to be updated because of changes to our systems and processes or the law. We may also notify you in other ways from time to time about the processing of your personal information.

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