Digicel CCTV & Security Protocol Privacy Notice
Introduction
Welcome to the Digicel CCTV and Security Protocol Privacy Notice.
At Digicel, we respect your privacy and we’re committed to protecting your personal data, being transparent and earning your trust. We do so by embedding best-in-class privacy and security principles throughout our operations and building a data protection framework that works; a responsibility that we take seriously.
At our different locations, Digicel may employ the use of Closed-Circuit Television (“CCTV”) and various security protocols (i.e., Visitor Login Form) to support the safety and security of our employees, visitors, contractors, and property. To this end, we’ve prepared this Privacy Notice to give you clarity and transparency on how we may use your personal data processed through the operation of the CCTV system and any other security measures employed when you access our premises or enter our buildings, and to inform you of your privacy rights and how the law protects you.
1. Data Controller
Digicel Jamaica Limited (“Digicel” or “we”, “us”, “our” in this privacy notice) is the data controller responsible for the information processed during the operation of our CCTV system and any other security measures employed under the scope of this notice.
We have a Group Privacy and Data Protection Team that handles all enquiries relating to the privacy practices of Digicel. If you’d like to enquire about this privacy notice, our privacy practices or your legal rights, you may contact our Privacy Team or Data Protection Officer, using the following details:
Post: Digicel Jamaica Limited, 14 Ocean Boulevard, Kingston, Jamaica
Attention: Group Privacy & Data Protection – Group Compliance, or Data Protection Officer
Email: privacy.ja@digicelgroup.com
Telephone: (876) 619-5187
Website: https://corporate.digicelgroup.com/en/privacy-and-trust
2. The Data We Collect About You
Our CCTV cameras record video images of individuals moving through monitored areas, including but not limited to, parking lots, entry or hallways, lobbies or waiting areas, restricted areas, and open, communal workspaces. These recordings may include identifiable features, movement patterns, and vehicle details such as licence plates.
Time, date, and location information are automatically captured as part of the recording process. Unless specifically noted, our CCTV system does not record audio. Cameras are never installed in restrooms, or any other area where individuals have a reasonable expectation of privacy.
Digicel also uses electronic access-control systems to protect our facilities, verify identity, and maintain an accurate record of all persons entering or moving within our buildings. This includes data generated when employees, contractors, or visitors use access cards, badges, or temporary passes to enter secured doors, floors, or other controlled areas. Access-control logs may record the badge identifier, the access point used, and the corresponding time and date of each swipe.
When you enter Digicel premises as a visitor or contractor (or any other unregistered stakeholder seeking access to our facilities) (“visitors”), you may be required to complete a Visitor Login Form, which collects basic personal information such as your full name, contact number, and a photograph for identification. You will also be asked to indicate the purpose of your visit and the individual or department you are meeting. Depending on the nature of your visit, security personnel may issue a visitor badge or temporary pass, and your badge activity (such as entry and exit events) may be logged as part of our access-control records.
3. Purposes of Processing Your Personal Data
Our CCTV and security protocols are used to maintain the security of our premises, ensure the safety of people on the property, prevent and detect crime, support investigations into incidents or accidents, and manage access to restricted or sensitive areas. These purposes help us protect our operations and uphold a safe environment for all individuals entering our locations.
Processing of your personal data is carried out in line with the Jamaica Data Protection Act, 2020 (“JDPA”), and Digicel’s Data Protection Policy. Digicel collects and processes visitor data under the lawful basis of legitimate interests in security and safety.
Personal Data on Minors
Our CCTV and security protocols may capture data on minors if they enter our premises and seek to access our facilities. Regardless, we don’t knowingly process personal data on individuals under the legal minimum age without the permission or under the guidance of a parent or guardian. If you believe we’ve inadvertently come into contact with information of a minor under your care without your permission, you can contact us and request that we delete the information.
4. Lawful Basis for Processing
Digicel processes visitor information primarily on the basis of legitimate interests under the JDPA. Digicel has a legitimate interest in knowing the identity of individuals that are granted access to offices within our buildings to ensure the safety of personnel, visitors, contractors, assets and property. Collecting visitor information is necessary for this security purpose and is a standard, non-intrusive practice used to manage identity verification, badge issuance, access control, emergency preparedness, and incident response.
In some situations, Digicel recognises that other legal bases may also arise. For example, if an incident occurs on site, Digicel may have a legal obligation to report the incident and retain related records for a specified period, or it may be necessary to process your information to protect your vital interests or those of others (for instance, accounting for your presence during a disaster or using your contact details during an emergency).
For more information on our lawful basis for processing your data in this regard, you may contact our Data Protection Officer at privacy.ja@digicelgroup.com.
5. Data Retention
Our CCTV footage and visitor log information is retained only for as long as necessary to fulfill the purpose of managing and auditing facility access. Digicel’s policy is to store CCTV footage and visitor sign-in records for a limited period after your visit, after which the records are removed from our active systems. In general, information is purged from the system quarterly and at any rate, within ninety (90) days of capture; however, it may be kept for up to one (1) year or longer if flagged to investigate a detected incident; pursue or defend a legal claim or; to comply with a legal requirement.
When the retention period lapses, we securely delete or destroy your personal data from the visitor records. For electronic records, this means the data is permanently erased from our databases in a manner that prevents recovery. For any paper sign-in sheets or printed logs (if ever used as backup), we shred or dispose of them as confidential waste. By doing so, we ensure that your name, contact details, photo, and other visit information are completely removed from our systems when no longer needed, in accordance with Digicel’s Data Protection Policy.
6. Disclosures of Your Personal Data
Your data is kept confidential and is accessible only to authorised personnel. We do not sell, share or otherwise disclose your personal data to any third party without your consent, unless required by law. Data collected by the CCTV and Visitor Login may be shared with or accessed by the following third parties for the purposes outlined:
| Data Processor | Location of Processing |
|---|---|
| Microsoft Corporation | USA |
7. Data Security
Digicel protects the visitor’s log information with appropriate security measures. We store your data in a secure electronic database that only authorised Digicel personnel can retrieve it. We have implemented industry-standard safeguards to prevent unauthorised access, alteration, or loss of your data. Please note that while we take all reasonable steps to protect your information, no data transmission over the internet can be guaranteed to be 100% secure.
8. Notification and Transparency
To ensure transparency about how we use your visitor information, we will explain the collection and use of visitor data via public signage, at the reception / security desk and, where applicable, on the Visitor Login Form itself. By proceeding to sign in, visitors acknowledge that their information will be processed for security and access control purposes in accordance with this Notice.
9. Your Legal Rights
Under the JDPA, visitors whose personal data we collect through our CCTV and Visitor Login Form have the right of access their personal data. You may request confirmation of whether Digicel holds visitor records about you and request a copy of that information, including the details you provided, and the dates/times recorded.
If you wish to enquire about or exercise any of the rights set out above, please visit our Privacy & Trust Centre or contact the Data Protection Officer at privacy.ja@digicelgroup.com.
10. Contact Information
If you have questions about this notice or wish to exercise any of your rights, please contact our Group Privacy Team or Data Protection Officer at privacy.ja@digicelgroup.com, or using the additional information provided under Item 1 above.
11. Updates to This Notice
We may update this CCTV and Security Protocol Privacy Notice from time to time to reflect changes in our practices or legal requirements. The latest version will always be available through our visitor materials and online privacy portals.