Camera Monitoring Policy

BestDrive wish to advise that we operate CCTV cameras in all our locations to ensure that we protect our Customers and our Staff. The CCTV cameras are only used to monitor the areas around our branch that are of interest to us for health and safety as well as company security, and we only share the material that we collect with our insurers or the Gardai as appropriate.

All standard GDPR guidelines are being followed by BestDrive at all times, and our full policy is available here for you to review.

BESTDRIVE CAMERA MONITORING PRIVACY NOTICE

BACKGROUND

This Camera Monitoring Privacy Notice (Notice) is issued by Advance Tyre Company Limited of Advance House, John F. Kennedy Drive, Dublin 12, D12 NRP4 (BestDriveourus and we). This Notice sets out how BestDrive processes your personal data via our use of CCTV cameras to view and record individuals or vehicles on and around our premises. In this Notice we will refer to the use of CCTV cameras collectively as ‘Camera Monitoring’. This Notice outlines how and why we will process personal data collected via Camera Monitoring in accordance with data protection law and best practice.

BestDrive will use your personal data only for the purposes set forth below and in compliance with Data Protection Laws (which includes the Data Protection Acts 1988 and 2003 (the “Acts”) and any subsequent, replacement or superseding legislation or regulation including Regulation EU/2016/679, also known as the General Data Protection Regulation (“GDPR”).

BestDrive is the controller of your personal data collected via Camera Monitoring. If you have any questions about our use of your personal data, please contact our Data Protection Officer, Advance House, JFK Drive, Naas Road, Dublin 12 – 01 4080900 or email

marketing@bestdrive.ie.

THE PERSONAL DATA WE COLLECT FROM YOU

Our Camera Monitoring will capture CCTV footage of you on and around our premises.

WHY WE PROCESS YOUR PERSONAL DATA VIA COURSE OF CAMERA MONITORING

We process your personal data via Camera Monitoring for the following purposes:

To protect the security and integrity of our premises and assets;

To prevent and record crimes and damage, disruption, vandalism and other malicious acts against our premises and assets; for the personal safety of staff, customers, visitors and other members of the public and to act as a deterrent against crime including fraud;

To support law enforcement bodies in the prevention, detection and the prosecution of crimes;

To assist in the investigation of any disciplinary matters or breaches of the employment contract or our internal policies and procedures, and in any related employment process;

To assist in ensuring the health and safety of staff and others; and as necessary for the exercise and defence of legal claims.

We process your personal data for each of the above purposes on the legal basis of pursuing our legitimate interests (Art. 6 Para 1. Lit. f)

GDPR). This means that we have considered that each of the above purposes are, on balance, legitimate because the interests we are pursuing are not overridden by the impacts on you.

Please note that NO automated decision making takes place based on the recordings.

This list is not exhaustive and other purposes may become relevant. We will update this Notice as appropriate with any new purposes.

VIEWING OF CAMERA MONITORING PERSONAL DATA

Images are only viewed by authorised BestDrive personnel. All staff using Camera Monitoring are given appropriate training to ensure they understand and observe the legal requirements related to the processing of the data that has been collected.

HOW WE SECURE PERSONAL DATA GATHERED BY CAMERA MONITORING

In order to ensure that the rights of individuals recorded by our Camera Monitoring are protected, we will ensure that data gathered is stored in a way that maintains its integrity and security.

Given the large amount of data generated by Camera Monitoring, we may store video footage using a cloud computing system. We will take all reasonable steps to ensure that any cloud service provider maintain the security of our information, in accordance with industry standards.

Where we engage data processors to process data on our behalf, we ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.

RETENTION PERIODS FOR CAMERA MONITORING PERSONAL DATA

We retain personal data which we collect in the course of Camera Monitoring for approximately 30 calendar days from the date of recording unless we identify a need to retain such personal data for a longer period of time, such as because it is necessary in relation to a specific investigation, because law enforcement authorities have requested that we retain such personal data, where there has been an accident or where a crime is suspected.

Where there is no need to retain such personal data, it will be deleted immediately upon expiration of the nominated retention period.

DISCLOSURE OF PERSONAL DATA GATHERED BY CAMERA MONITORING

We may share this personal data with our group companies (the Continental AG group) and other associated companies or organisations, for example, our shared services partners where we consider that this is necessary for any of the purposes set out above.

Your personal data will be passed on to investigative authorities, processors (external camera maintenance service provider) or lawyers on an ad hoc basis.

Our camera maintenance service provider processes your data as our processors on the basis of a corresponding data processing agreement.

No personal data from our Camera Monitoring will be disclosed to any other third party without express permission being given by our Data Protection Officer. Such personal data will not be released unless satisfactory evidence that it is required for legal proceedings, or a court order, has been produced. In appropriate circumstances, we may disclose such personal data to the Gardaí or other law enforcement agencies where this is required in the detection or prosecution of crime.

We will maintain a record of all disclosures of such personal data. No personal data from our Camera Monitoring will ever be posted online or disclosed to the media.

YOUR RIGHTS

You have the following rights under applicable law, subject to certain exceptions, with respect to your personal data:

Right of Access. You may request a copy of the personal data that we process about you.

Right to Rectification. You may ask us to correct any inaccurate or incomplete personal data.

Right to Erasure. You may request that we delete the personal data that we have about you in certain circumstances, for example where it is no longer necessary for us to process it.

Right to Restriction of Processing. You have the right to request that we restrict the processing of your personal data under certain circumstances.

Right to Object. You have the right to object to your personal data being processed on the basis of our legitimate interests (or those of a third party). We will cease processing your personal data, unless the processing is based on compelling legitimate grounds which override the impact on you or is needed for the establishment, exercise or defence of legal claims.

You also have the right to lodge a complaint with the Data Protection (DPC) in relation to our processing of your personal data at any time. Contact details for the DPC are available here.

Revised August 2023