Birmingham Airport Visitor CCTV and Thermal Imaging Privacy Notice

Birmingham Airport Visitor CCTV and Thermal Imaging Privacy Notice

Birmingham Airport is collecting your personal data.  When we collect personal data, we are obliged legally to provide you with certain information, it is called the “Right to be Informed”.  That information is contained in the below Notice.  If any of the information we provide to you is not clear enough, there are contact details for Birmingham Airport’s Data Protection Officer further down this Notice, please do not hesitate to make contact and ask for further information.

1. Why we need it - the purpose of processing

Birmingham Airport has CCTV across its infrastructure, including the terminal. CCTV will capture images in real time in whichever direction the cameras are pointed, and these cameras will capture footage of you whilst you are on the premises. Cameras have been situated both inside and outside the buildings. 

We are collecting and processing personal information via the CCTV systems for the following purposes: 

  • To ensure the health and safety of Airport visitors.
  • To detect, prevent or reduce the incidence of crime.
  • To prevent and respond effectively to all forms of possible harassment and disorder.
  • To reduce the fear of crime.
  • To create a safer environment.
  • To provide emergency services assistance.
  • *To monitor the use of IT systems, and their users, throughout the airport for security purposes.
  • *For security compliance & performance monitoring and measuring.
  • *To monitor operational standards throughout the airport, including contractual agreements with partners.

*Operational concerns are not normally a reason to operate a CCTV system, they are not necessary or appropriate for something so intrusive.  However, the airport is a unique environment.  Where an operational issue is highlighted and there may be security concerns, the CCTV system will be used to check those operations, where necessary and appropriate.

1a.   COVID-19 Thermal Image Screening

In response to the COVID-19 pandemic, Birmingham Airport will record your skin temperature through a thermal imaging device ‘bolted on’ to our existing CCTV cameras. Thermal imaging cameras will only be located at the entrance to the terminal building, with a portable camera available to allow for greater privacy, such as the removal of religious garments. The portable device may also be used where an initial scan has shown a temperature of above 38 degrees and the individual wishes to be re-tested following a short rest period.

Health data will be captured to identify any individual with a skin temperature above 38 degrees, as a high temperature is a symptom of COVID-19. This reading will be taken from a distance at the forehead. Access to the terminal building will be denied to those with a skin temperature of 38.1 degrees, and above, as a precaution to safeguard all visitors and staff from exposure to COVID-19.

Birmingham Airport will be guided by Public Health England and World Health Organisation advice. Thermal imaging technology will only be used in the context of a pandemic and will be disabled when the level of risk to visitors and staff has lowered to an acceptable level.  

2. Why we’re allowed to process your personal information in this way – the legal basis

To process your personal information via CCTV we are relying on the following schedule 2 conditions of the GDPR. If you do not understand any of the following and would like clarification, please contact the Data Protection Officer on details at the bottom of this notice.

  • To comply with a legal obligation - to comply with Department for Transport Regulations regarding CCTV systems within the Airport.
  • Necessary for the public interest *

*Thermal imaging data will be processed in the public interest. Birmingham Airport, as a port of entry in to and out of the UK, must take measured to reduces the opportunity for visitor and staff exposure to COVID-19, as well as limit the domestic and international spread of the virus.

Who we will share your personal information with?

There is a small amount of CCTV that is shared with our crime partners, as listed below.  There are Information Sharing Agreements in place to document how the airport shares the CCTV footage with other organisations lawfully.

Currently we share limited CCTV footage with the following;

West Midlands Police

The UK’s Counter Terrorism Unit

UK Border Force

Internally CCTV footage will only be processed by airport staff who are authorised to do so and any other departments where a legitimate and lawful reason for their involvement is required.  All access is monitored and recorded.

Thermal images will be processed by Mitie employees through a live feed, at a security podium. This is to enable Mitie staff to identify those with a temperature above 38 degrees and approach that individual to prevent entry into the Terminal. Your stored thermal images will not be shared with any third-party and will not be used for any other purpose.

4. Where your personal information will be stored or transferred to

CCTV (including thermal imaging) Footage:

  • Will be stored on secure Airport servers based within the UK.

5. How long we will keep your personal information for

The CCTV system will keep footage for 31 days, at which point it will be automatically overwritten; this includes thermal imaging footage and temperature readings.

Any footage which is pulled from the system for official purposes will be subject to departmental retention schedules.  If you have any questions surrounding these department specific retention timescales, you can request that information from the Data Protection Officer, whose details are at the bottom of this Notice.  

6. Your rights

You are entitled to request the following from Birmingham Airport.  These are called your Data Subject Rights and there is more information on Birmingham Airport’s website about each of these and what they mean to you.  You can find this information by going to birminghamairport.co.uk/dataprotection

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to data portability
  • Rights with regards to automated individual decision making, including profiling

Right to object

The right to object is particularly important if we are processing your information under the conditions of a “public task”, or “legitimate interests”, and you can check that information above in section 2.  These is because these conditions must be based on not overriding your rights and freedoms against our purposes for using your personal information.  If we are using your personal information on these grounds and you wish to object, please contact us on

[email protected]

If you have any questions, or wish to contact us and ask us to look at your rights at any time, please contact Birmingham Airport’s Data Protection Officer on the below details.

Postal Address:

Birmingham Airport Limited

Diamond House

Airport Way

Birmingham

B26 3QJ

Email: [email protected]

7. If you are unhappy with the way in which we use your personal information

If you are unhappy with the way in which Birmingham Airport has used your personal information and you have already been in contact with us (on the above details) and feel we did not resolve your issues to your satisfaction, you can contact the Information Commissioners Office (The UK’s Data Protection Regulator), the details are below.  However, the Information Commissioner does prefer that you have contacted Birmingham Airport first with your concerns before you then take those concerns to the Regulator.

Postal Address:

Information Commissioners Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Email: [email protected]

Telephone number: 0303 123 1113 for local rate calls or 01625 545745 for the national rate

8. Is your personal data being processed because of a regulatory or contractual requirement?

Birmingham Airport is required by to law let you know if any of the information we process about you for the CCTV is either a statutory requirement or as part of any contract we have in place with you.

There is a regulatory requirement for certain cameras, in certain areas, due to Department for Transport Regulations.

9. Are we using automated decision making or profiling with regards to your personal data?

No.

Any further questions about how we use your personal information in regard to the CCTV, that has not been covered in this notice or there is any information above that you do not understand, please contact the Data Protection Officer on [email protected]

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