CCTV Privacy Notice

Personal Data Protection Policy Notice For the Use of CCTV

          Thaniya Co., Ltd., of No. 52, Silom Road, Bangkok; Thaniya Real Estate Co., Ltd., No. 62, Silom Road, Bangkok; Yada Development Co., Ltd., No.56, Silom Road, Bangkok, No.59, Sukhumvit 16, Bangkok; Bhatra Co., Ltd., No.51, Sukhumvit 16, Bangkok; Thanyaville Co., Ltd., No.735,735/1-8, Srinakarind street, Bangkok; Thaniya Medical Center Co., Ltd., No. 52, Silom Road, Bangkok; Thaniya Dental Center Co., Ltd., No.52, Silom Road, Bangkok, Springfield At Sea Co,. Ltd., No.208, 208/1, Sampraya Subdistrict, Petchaburi, Springfield at Sea Co., Ltd., of No. 858, 858/1-2, Cha-Am subdistrict, Petchaburi, Springfield Royal Countryclub Co., Ltd., No.208, Sampraya Subdistrict, Petchaburi (hereinafter collectively referred to as “Company”) are currently using CCTVs to monitor activities of its staff, operators, clients, employees, contractors, visitors, or any other persons (hereinafter collectively referred to as “you”) inside and around Thaniya Plaza Building, Thaniya BTS Building, Yada Building, Thaniya Road, Yada Road, Mayfair Garden Building, Gardina Asoke, Thanyapark Building, Springfield Village Golf and Spa, Springfield At Sea (hereinafter collectively referred as “Premises”) to protect life, health and properties. The Company will collect your Personal Data by using the said CCTVs upon your entry into the Premises.

           This CCTV Privacy Notice (“Privacy Notice”) describes how the Company collects, uses or discloses your personally identifiable information (“Personal Data”), including your relevant rights as follows:

1. Lawful Basis for Data Processing

The Company will collect your Personal Data on the following lawful bases:

1.1 Necessity for protection of interests essential to life, bodily integrity, or health of yours or other natural persons;

1.2 Necessity for protection of legitimate interests of the Company or other persons which are of no less importance than your fundamental rights over personal data;

1.3 Necessity for compliance with laws related to the protection of occupational safety and health, and the protection of the Company’s properties.

2. Purpose of Processing Your Personal Data

The Company will collect your Personal Data for the following purposes:

2.1 To protect your health and personal safety, as well as your properties;

2.2 To prevent the Company’s buildings, facilities, and properties from any kind of destruction, vandalism, or other types of crimes;

2.3 To support law enforcement agencies in  suppression, prevention, investigation, and legal proceedings;

2.4 To facilitate a dispute resolution during a disciplinary process or after a complaint is filed;

2.5  To facilitate an investigation or complaint processing;

2.6  To facilitate the filing or prevention of a civil lawsuit, including but not limited to, legal proceedings related to labor disputes.

3. Personal Data  To Be Collected

         Pursuant to the purposes defined in Article 2., the Company will install CCTVs in visible locations with a caution sign that the place is under CCTV monitoring. In the collection of your personal data upon entry into the Premises, CCTVs will be installed at the Premises’ entrances, exits, and other locations deemed as requiring monitoring by the Company.

Your Personal Data that are to be collected are as follows:

Still images;

Moving images;

Voice;

Photos of your belongings e.g. vehicles, bags, hats, clothes, etc.

          In this regard, the Company will not install the CCTVs in locations that may unduly cause a violation of your fundamental rights such as in toilets, rooms used for accommodation, etc.

4. Retention Period

         For the purpose of monitoring activities by CCTVs under this Privacy Notice, the Company will retain your Personal Data in the CCTVs for 45 days (forty-five days) from the date of recording. After the expiry of the said period, your Personal Data will be deleted or destroyed.

5. Disclosure of Your Personal Data

            The Company will keep any data concerning you collected by CCTVs confidential and shall not disclose them unless they are made for the purpose of monitoring under this Privacy Notice. The Company may disclose the Personal Data stored in CCTVs to any of the following persons:

5.1 Competent authority for the purpose of facilitating a legal enforcement, investigation or legal proceedings;

5.2 The Third-party security providers to ensure the prevention of any harm to life, body, health, or properties of yours or other persons;

5.3 Suppliers and/or maintenance providers of CCTV systems to maintain and repair CCTV systems in accordance with the purposes described in Article 2 above.

6. Your Rights under Personal Data Protection Act B.E. 2562 (2019)

         Personal Data Protection Act B.E. 2562 (2019) aims to grant you with more control over your Personal Data. You will be enabled to exercise your rights under the Personal Data Protection Act B.E.2562 (2019) after the provisions relating to the data subject’s rights entered into force, which include the following:

6.1 The right to revoke your consent to have your Personal Data processed by the Company;

6.2 The right to access your Personal Data, obtain a copy of your Personal Data, and request for a disclosure of the source from which the Company collected your Personal Data, except in cases where the Company is granted the right by law or court order to decline your request, or where your request can be detrimental to right or freedom of the others.

6.3 The right to data portability, whereas you may obtain your Personal Data from the Company in a format readable by an automated machine or device and may automatically process (wherever possible using automated means) and transmit such data to other data controllers except when that the processing and transmission are technically infeasible;

6.4 The right to object to the collection, use, or disclosure of your Personal Data except in cases where the Company has  legal rights to  refuse your request (e.g. the Company is able to prove that the Company’s collection, use, or disclosure of your Personal Data is based on better legal grounds, or is made for the constitution, compliance, or exercise of legal rights, or for public interests as stated in the Company’s missions.)

6.5 The right to request the Company to delete, destroy or make your Personal Data no longer identifiable;

6.6 The right to request a restriction of processing of your Personal Data in any of the following cases:

6.6.1 Your request to rectify your Personal Data, or to keep your Personal Data complete and current is being reviewed by The Company;

6.6.2 Your Personal Data is unlawfully collected, used or disclosed;

6.6.3 The retention of your Personal Data is no longer necessary to fulfill purposes of the data collection as stated by the Company,  but you request the Company to continue retaining the data for the purpose of exercising your right under the law;

6.6.4 In response to your objection to the collection, use, or disclosure of your Personal Data, the Company is currently proving that the said actions are conducted with legal justifications, or reviewing that the said actions are conducted with necessity for public interest.;

6.7 The right to rectify your incorrect or incomplete Personal Data to keep it correct, complete, current, and not misleading;

6.8 The right to file a complaint in case of any breaches of the Act or any of its subordinate legislations by the Company.

7. Data Security

           The Company has put in place appropriate technical and management measures to prevent your Personal Data from being lost, accessed, deleted, destroyed, used, altered, changed, or disclosed without any authorization in accordance with the Company’s Information Security Policy.

         The Company also publishes its internal Data Privacy Policy and guidelines to ensure data security when processing your Personal Data to maintain confidentiality, integrity, and availability of your Personal Data. The Company will review the said policy periodically as deemed appropriate.

8. Data Controller’s Responsibility

            The Company will allow only its authorized personnel who are needed to collect, use or disclose your Personal Data for the purposes described in this Privacy Notice to access your Personal Data. The Company will ensure that they fully comply with this Privacy Notice.

9. Amendments to The Privacy Notice

            The Company reserves its right to amend this Privacy Notice as deemed appropriate. Details on the amendment will be provided on http://www.thaniyagroup.com/. However, it is advisable that you keep checking this Privacy Notice for the latest updates, especially before you enter the Company’s Premises.

           By entering the Premises, you hereby consent to the terms under this Privacy Notice. Please refrain from entering the Premises if you disagree with this Privacy Notice. If you continue to enter such Premises after this Privacy Notice is rectified and published via the channel mentioned above, you will be deemed as having acknowledged the changes made to this Privacy Notice.

10. Contact Details

For inquiry regarding this CCTV Privacy notice, you may contact us at:

Thaniya Co., Ltd.

No.52, Silom Street, Suriyawongse District, Bangkok

Website:               http://www.thaniyagroup.com/

Phone number:    02-231-2244

Email:                    pdpa@Thaniyagroup.com

11. Appropriate Authority

            If you wish to report any issue or feel that the Company does not respond to your inquiry properly, you may contact and/or lodge a complaint to the Office of the Personal Data Protection Committee (PDPC) at:

                Office of the Personal Data Protection Committee (PDPC)

Phone number:   02-142-1033

Email:                   pdpc@mdes.go.th

Website:              https://www.mdes.go.th/mission/82

Facebook:            https://www.facebook.com/pdpc.th

Address:              Office of the Personal Data Protection Committee (PDPC)

           No.120, Moo.3, Rattaprasassanaphakdi Building (B Building)

           Changwattana Government Complex, Changwattana Street,

           Thung Song Hong Subdistrict, Lak Si District, Bangkok 10210