Privacy Policy on CCTV Use

Privacy Policy on CCTV Use

Terms and Policy

Privacy Policy on CCTV Use

This privacy policy (“Policy”) on the use of closed-circuit television (“CCTV”) devices describes how YKK (Thailand) Co., Ltd. (hereinafter referred to as the “Company”, “we”, “us”, or “our”) use CCTV devices and its system for monitoring our specific space within and around our premises, buildings and facilities for protecting life, health, and property.

The Company collects individually identifiable information of all employees, directors, shareholders, business partners, customers, non-employed workers, contractors, visitors and any other persons (collectively referred to as “you” or “your”) entering the monitored areas through the use of such CCTV devices (“Personal Data”).

We are committed to ensure that your Personal Data is processed in accordance with applicable laws and regulations in the jurisdictions we operate (“Applicable Laws”). If you provide any Personal Data to us, you understand we will only collect, use, disclose and/or transfer your Personal Data in accordance with this Policy. You do not have to provide Personal Data to us, however where the data we collect is necessary or legally required in relation to our potential and existing relationship with you, if you do not agree or provide the Personal Data, it may affect our ability to carry out any transaction with you and/or employment related request.

WHY WE COLLECT, USE AND/OR DISCLOSE YOUR PERSONAL DATA AND ON WHAT LEGAL BASIS

The Company may collect your Personal Data under and for several legal bases and purposes as follows: –

  1. To prevent, protect and/or suppress danger to your personal life, body, health and belongings;
  2. To protect our buildings, facilities and assets from damage, disruption, vandalism, and other crime;
  3. To assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings;
  4. To assist in the investigation or proceedings concerning a whistleblowing complaint;
  5. To assist in the establishment or defense of any civil and criminal proceedings;
  6. To comply with Applicable Laws, including but not limited to, the laws regarding environment and workplace safety; and
  7. To support law enforcement authorities and agencies in the deterrent, prevention, detection, and prosecution of crime.

The Company will balance our legitimate interest and that of any relevant third parties, as the case maybe, and your fundamental rights and freedoms related to the protection of the Personal Data concerning you. We will also endeavor to identify any steps required to achieve the right balance as appropriate.

WHAT PERSONAL DATA WE COLLECT

  • Pictures
  • Moving footages
  • Sounds (e.g., audios and/or voices)
  • Pictures of your assets such as vehicles, bags, hats, clothing, etc.
  • Other identifiable source of information as observable by CCTV

The Company installs CCTV in visible locations and will not install CCTV in areas that may unreasonably infringe upon your fundamental rights, such as a worker’s resting place.

TO WHOM WE MAY DISCLOSE YOUR PERSONAL DATA

Company will keep your Personal Data confidential and will not disclose it unless we have a necessity to achieve the purposes set out in Item 1 of the Policy. We may disclose your Personal Data to the following parties: –

  1. Our subsidiaries and affiliated companies under YKK Corporation – for our legitimate interests in order to achieve the purposes provided in this Policy;
  2. Governmental and/or regulatory agencies to support or assist law enforcement authorities and/or agencies with regards to any investigation and prosecution of civil or criminal proceedings;
  3. Third-party service providers such as external advisors and auditors – as our necessary steps for protection of your personal health, safety, and belongings; and
  4. Others (if any).

CROSS-BORDER DATA TRANSFERS OF YOUR PERSONAL DATA

The Company may disclose and/or transfer your Personal Data outside of Thailand, to affiliated companies under YKK Corporation, where necessary to ensure the safety of your personal life, health and/or body. It may also be necessary for us to disclose your Personal Data to third parties located overseas in connection with the purposes set out in this Policy. We will obtain your consent for such disclosure and/or transfer unless there are other compelling legitimate bases or other cross-border mechanisms as permitted by Applicable Laws for us to conduct so without obtaining your consent.

Notwithstanding so, we will ensure that the transfer of Personal Data outside of Thailand is in compliance with Applicable Laws that is in effect at that time of the transfer.

YOUR RIGHTS AS A DATA SUBJECT

Subject to the Applicable Laws and exceptions thereof, you may have the following Rights relating to your Personal Data:-

  1. Access: You may have the right to access or request a copy of your Personal Data we collect, use and/or disclose;
  2. Rectification: You may have the right to request for rectification of incomplete, outdated, inaccurate or misleading Personal Data that we collect, use and/or disclose;
  3. Data portability: You may have the right to obtain your Personal Data we hold, in a structured, electronic format, and to transmit such data to another party (data controller), where this is personal information which you have provided to us, and if we had collected, used and/or disclosed that data on the basis of your consent. However, we may reject your request if your exercise of such right violates any right or freedom of any other person or we have to use your Personal Data for the purposes of public interest or legal compliance.
  4. Objection: You may have the right to object to certain collection, use and/or disclosure of your Personal Data subject to the Applicable Laws;
  5. Restriction: You may have the right to restrict our use of your Personal Data in certain circumstances;
  6. Withdraw consent: For the purposes you have consented to our collection, use and/or disclosure of your Personal Data, you may have the right to withdraw consent in certain circumstances ;
  7. Deletion: You may have the right to request that we delete, destroy or anonymise your Personal Data that we collect, use, and/or disclose, except we are not obligated to do so if we need to retain such Personal Data in order to comply with a legal obligation or to establish, exercise or defend legal claims; and
  8. Lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe that we are not in compliance with the Applicable Laws. However, we ask that you contact us first about any complaints before contacting the relevant authorities so that we have an opportunity to address your complaints.

HOW LONG DO WE KEEP YOUR PERSONAL DATA

The Company will only retain your Personal data for as long as reasonably necessary to fulfil our duties to achieve the objectives prescribed in this Policy. We will remove your Personal Data from our systems and records when we are no longer permitted by the applicable laws to store your Personal Data.

In the event a judicial or disciplinary action is initiated, your Personal Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by the Applicable Laws.

SECURITY MEASURES TO PROTECT YOUR PERSONAL DATA

The Company maintains appropriate security measures and has an information security policy in place, to guide and maintain the security of your personal information, both technically and administratively, in order to prevent data loss, unauthorised access, deletion, modification, or disclosure of your Personal Data, and/or other similar risks.

OUR RIGHTS TO AMEND THIS POLICY

The Company reserves the right to amend and update this Policy in its sole discretion at any time without prior notice. We encourage you to check the Company’s website for updates of this Policy, especially before you enter any of the Company areas. By entering the Company premises, you agree with all the terms in this Policy and consent to the collection, use and/or disclosure of your Personal Data for the purposes set out in this Policy.

OUR CONTACT DETAILS

If you have concerns or questions regarding this Policy or if you would like to exercise your Rights in relation to your Personal CCTV Data, please contact us at:-

Contact person: Ms. Jurairat Gotan
Address: 689 Moo 6, Sukhumvit k.m. 35, Bangpoomai, Muang District, Samutprakarn 10280
Contact number: 02-323-9041 (Ext. 132)
Contact email address: Jurairat_g@ykk.com