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This document provides information on the methods employed by Airbox Fulfilment LTD and Airbox Fulfilment BV (hereinafter referred to as “Airbox fulfilment”, “us” or “we”) to process personal data concerning natural persons entering the premises monitored by the camera monitoring system and persons registered in a different way when they enter our buildings or premises through the operation of the camera monitoring system and other security measures, and on the method employed to treat and protect such data.
The purpose of this Notice of the CCTV Privacy Notice (hereinafter referred to as the “Privacy Notice”) is to inform you of the method that we employ to collect and process your personal data related to the operation of the camera monitoring system and to inform you of your rights and the way in which you can exercise such rights.
We strongly recommend that you carefully familiarise yourself with this Privacy Notice. If you have any questions about this notice or how we use CCTV, please contact us using the details below.
The Controller of your personal data is one or more of the following companies depending on the buildings and premises of the Airbox Fulfilment that you enter:
Airbox Fulfilment Ltd
Company number: 10828225
Registered office:
Airbox Fulfilment, Unit 18 Ascent Logistics Park North, Fraserfields Way, Leighton Buzzard, LU7 3RJ
Email: info@airboxfulfilment.com
Telephone: +44 (0)20 8283 0200
Airbox Fulfilment Ltd is the data controller for CCTV footage collected at UK premises.
Information Commissioner’s Office (ICO): www.ico.org.uk
Point of contact: Rich Carrington, Head of Training and HR
Airbox Fulfilment B.V.
Registered office: Zoetermeer, Netherlands
KvK number: 93001991
Airbox Fulfilment B.V. is the data controller for CCTV footage collected at Dutch premises.
Autoriteit Persoonsgegevens (AP): www.autoriteitpersoonsgegevens.nl
Contact details for any personal data protection concerns are as follows:
E-mail: info@airboxfulfilment.com or hr@airboxfulfilment.com
Address details per region/country in question are outlined above for written communication via postal service.
Your personal data may be processed through a CCTV system with video recording. This processing is carried out on the basis of our legitimate interest for the purposes of protecting property, ensuring workplace safety, and safeguarding the security of individuals present within our premises.
CCTV operates in designated areas of our warehouse and office sites where monitoring is necessary for security and operational protection. The Camera Monitoring System (CCTV) is comprised of cameras that monitor the outdoor areas of the buildings and premises, common handling areas, entrance doors, gates and driveways leading the premises. The cameras are installed in a manner that allows for the areas to be monitored and recorded without excessively disturbing the right to privacy of persons being monitored – the CCTV systems employed will monitor either video, audio or both video and audio.
The cameras record colour surveillance footage on a continuous basis. Personal data included in audio and video surveillance footage recorded by the cameras is retained on the recording device for a period not typically exceeding 30 days allowing us any possible incident to be investigated together with collecting other information necessary for the handover of the video surveillance footage to the bodies responsible for criminal proceedings or insurance company, provided that this is required for the protection of our legitimate interests while adhering to handover conditions compliant with the current interpretation of relevant legislation. After this period, footage is automatically overwritten unless it has been securely retained for a specific ongoing investigation or legal matter. Certain parts of the records (including personal data contained therein) may be retained on a selective basis for a longer period to determine, exercise or defend our legal claims or on the grounds of our legitimate interest.
Video surveillance footage from the camera monitoring system may only be disclosed to bodies responsible for criminal proceedings, courts or administrative authorities for the purposes of administrative or criminal proceedings. A list of potential 3rd party organisations in which we may disclose data to may include but are not limited to:
• Law enforcement agencies
• Courts and tribunals
• Regulatory authorities
• Insurers
• Legal advisers
• Professional advisers
• Other third parties where disclosure is necessary for the establishment, exercise or defence of legal claims
In limited circumstances, we may disclose CCTV footage to third parties, including clients, where we rely on our legitimate interests under Article 6(1)(f) UK GDPR and EU GDPR. Such disclosure will only take place where there is a genuine and proportionate business need, for example in cases involving serious fraud allegations, significant financial loss, insurance disputes, legal proceedings, police involvement or repeated chargeback fraud patterns. Before any disclosure is made, we assess whether it is necessary to achieve the stated purpose and whether the interests and rights of individuals captured in the footage are appropriately protected. Where disclosure is approved, it will be limited to the minimum footage required and may be subject to redaction and appropriate confidentiality safeguards.
External providers and supervisors of camera monitoring systems (CCTV) may now and then inspect the video surveillance footage based on our express instruction to do so in the case of failures and where technical interventions are required. Access and intervention of such persons is monitored and regulated by concluded agreements on personal data processing that guarantee at least the same level of data protection as this Privacy Notice.
We implement appropriate technical and organisational security measures to protect CCTV footage from unauthorised access, loss or misuse. At the same time, we take into account the state of technological development in order to protect your personal data from accidental loss, destruction, alteration, unauthorised disclosure or access. These measures may include, but are not limited to, taking reasonable steps to ensure the responsibility of the relevant employees having access to your data, employee training, regular backups, data recovery procedures and incident management, and software protection of devices on which personal data is stored etc.
You have the right to exercise your data protection rights in relation to CCTV footage, including the right to request access to your personal data. We may refuse or limit access where disclosure would adversely affect the rights and freedoms of others or where a request is manifestly unfounded or excessive.
If you are based in the United Kingdom, you may raise concerns with the Information Commissioner’s Office (ICO). If you are based in the Netherlands, you may contact the Autoriteit Persoonsgegevens (AP).
You have the right to request information on whether we process your personal data and to what extent. In addition, you have the right to request to be disclosed personal data that you have provided to us as well as other personal data concerning you as a person.
Considering the character of the processing, we can provide you with the information only if you provide us information based on which we can identify you on the video surveillance footage. Otherwise, we unfortunately cannot provide you with the required information. In addition, we reserve the right to refuse your request for access as unreasonable, particularly with the rights of third parties being affected.
A copy of your data recorded by the camera monitoring system (CCTV) will be provided only in cases where no rights and freedoms of third parties are affected and we can identify the part of the video surveillance footage containing your personal data based on information that you will provide to us. Third-party rights are affected in particular in cases where the requested part of video surveillance footage also includes the personal data of such third parties.
If you ask us to limit the processing of your personal data, for example, when you question the accuracy, legality or our need to process your personal data, we will limit the processing of your personal data to the minimum necessary (storage) and will only process it for determination, performance or defence of legal claims, or for the protection of the rights of another natural or legal person, or for other limited reasons prescribed by applicable laws. If the restrictions are cancelled and we continue to process your personal data, we will inform you without undue delay.
We process your personal data based on our legitimate interest to protect our property and ensure the security of our buildings. Therefore, you have the right to object to such processing for a reason concerning your specific situation. If in such a case, we are not able to demonstrate our serious legitimate reasons that outweigh your interests or rights and freedoms or if we fail to demonstrate that such data is necessary for the determination, execution and defence of our legal claims, we will no longer process such data and we will erase it without any undue delay.
You have the right to file a complaint regarding our processing of data with the your regional data protection office, for the example, in the UK, you would be able to contact the Information Commissioners Office to raise a complaint that could not be resolved directly with Airbox.
We are authorised to amend or update the Privacy Notice on a continuous basis. Any amendments of this Privacy Notice become effective upon their publication in the amended Privacy Notice, which can be found:
1) At the receptions of each individual premises
2) On the company SharePoint Online and on Rippling
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