Aerial Drone Services Privacy Notice

INTRODUCTION

This notice explains how we use autonomous drone surveillance across trading estates and other commercial centres to help prevent and detect crime, protect people and property, and support a safer environment for businesses, employees, and visitors. The drone system captures video footage of activities taking place within defined areas only. We only retain footage where it relates to a security incident or is otherwise necessary for the purposes described in this notice. All data is processed securely, reviewed by authorised personnel, and deleted in accordance with strict retention controls.

Argenbright Security Europe Limited (“ASEL”) is an integrated security solutions provider that delivers estate-wide security services across trading estates such as the Team Valley trading estate in Gateshead.

ASEL is the Data Controller for all personal data processed in relation to its autonomous drone surveillance operations.

Our drone solution provides enhanced aerial monitoring to support the prevention and detection of crime. The drones operate along predefined flight paths and respond to security alerts, capturing footage that helps our security officers and our Security Operations Centre assess incidents quickly, coordinate an effective response, and safeguard people and assets across the estates.

If footage does not relate to a specific incident, it is deleted automatically within a short period and cannot be recovered. This ensures that personal data is only retained when strictly necessary for legitimate security purposes.

ASEL operates this service to support the prevention of crime, reduce harm, and enhance safety for businesses, employees, and visitors, while also helping reduce demand on local policing resources.

You can identify areas monitored by our autonomous drone system through the clear surveillance signage we install at entry points and throughout the estates. This signage also includes a QR code linking directly to this privacy notice.

DEFINITIONS

Controller – Argenbright Security Europe Limited is the organisation which determines the purposes and means of the processing of personal data.

Processor – A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient – A natural or legal person, public authority, agency or other body, to which the personal data is disclosed, whether a third party or not.

Third Party – A natural or legal person, public authority, agency or other body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Personal Data – Any information relating to an identified or identifiable natural person (“Data Subject”) An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special Category Personal Data – Any information relating to an identified or identifiable natural person (“data Subject”) which falls into one of the following categories. Racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, data concerning a person’s sex life, data concerning a person’s sexual orientation.

Criminal Offence Data – Any information relating to criminal convictions, offences and related security measures. This includes any alleged and / or committed offences.

Data Subject – Any identifiable natural person, who’s personal data is processed by the controller responsible for the processing.

ASEL – Argenbright Security Europe Limited

Customer – ASEL Customer

Partners – Organisations with which we may share your data.

SOI – Subjects of Interest are individuals who are suspected of or have committed crime against our customer or security officers.

HOW TO CONTACT US

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights (described below) then please address your correspondence to.

Argenbright Security Europe Limited
Charles Babbage House, Kingsway Business Park, Rochdale, OL16 4NW

Alternatively, you can email us at dpo@asel.co.uk

We have also appointed a Data Protection Officer (DPO), if you do send correspondence by post, please mark the envelope to the ‘Data Protection Officer’.

OUR DATA PROTECTION OFFICER

The Data protection officer can be contacted by emailing dpo@asel.co.uk.

REASONS FOR PROCESSING YOUR INFORMATION

ASEL operates its autonomous drone surveillance system across Trading Estates for clearly defined and legitimate security purposes. The processing of your personal data, including video imagery, is carried out strictly to support the prevention and detection of crime, the protection of people and property, and the safe operation of the estate. The drones capture imagery only within designated operational areas and only for the purposes described below.

Preventing and Detecting Criminal Activity

The estate experiences a variety of crime and anti-social behaviour, including theft, criminal damage, vehicle crime, and attempted break-ins. Drone footage enables ASEL to:

  1. identify suspicious activity quickly,
  2. detect incidents as they occur,
  3. gather information that may support evidence-based decision-making, and
  4. deter individuals intent on committing criminal acts.

This is a core reason for processing the data and is essential to maintaining a safe environment for businesses, employees, and visitors.

Responding to Security Incidents in Real Time

The drone system allows for rapid aerial verification of alarms, reports of suspicious behaviour, or emerging incidents. Personal data may be processed when:

  1. drones are deployed to a specific alert,
  2. footage is used to assess the nature and seriousness of the incident, and
  3. officers rely on the footage to coordinate an appropriate and proportionate response.

This helps reduce harm, supports timely interventions, and enhances the safety of all persons on the estate.

Supporting Post-Incident Investigations

In cases where a security incident has occurred, ASEL may retain relevant footage to:

  1. understand what happened,
  2. assist affected businesses,
  3. support law enforcement enquiries,
  4. provide evidence for insurance or legal claims,
  5. analyse patterns of behaviour that could inform future crime-prevention measures.

Footage that does not relate to an incident is not retained and is automatically deleted.

Protecting ASEL Personnel and Estate Stakeholders

Personal data may be processed to safeguard ASEL staff, estate workers, visitors, and contractors. Drone footage helps ensure that responding officers have situational awareness and can approach incidents in a safe and informed manner.

Ensuring the Security and Integrity of the Estate’s Infrastructure

Drones may capture imagery relating to buildings, access points, vehicles, and other estate infrastructure. This helps ASEL:

  1. identify vulnerabilities,
  2. prevent unauthorised access,
  3. protect valuable assets, and
  4. maintain a resilient security posture across the estate.

Fulfilling Legal and Regulatory Obligations

ASEL may process and share footage when legally required to do so, including:

  1. complying with police requests for evidence,
  2. supporting investigations into unlawful acts,
  3. responding to regulatory or statutory obligations.

Ensuring Accountability and Service Quality

We may process personal data for internal audit, compliance, and quality assurance purposes, such as:

  1. reviewing how incidents were handled,
  2. ensuring correct operational procedures were followed,
  3. confirming that data-protection and governance obligations are being met.

All internal reviews involving footage are conducted under strict access controls and governance frameworks.

In summary, we process your personal data only when necessary to:

  1. prevent and detect crime,
  2. respond to incidents,
  3. protect people and property,
  4. comply with legal obligations, and
  5. maintain a safe and secure environment across the estates.

No processing takes place for marketing, profiling, automated decision-making, or any purpose unrelated to estate security.

WHAT DATA DO WE COLLECT AND PROCESS

To achieve our purpose, we collect the following personal data through our drone surveillance system:

  1. Video images captured by the drone’s onboard camera when operating across the Team Valley Trading Estate.
  2. Location and time data relating to where and when drone footage is recorded.
  3. Incidental images of individuals, such as employees, visitors, delivery drivers, or members of the public present within the operational area.
  4. Vehicle information, including vehicle appearance and number plates, if visible within the video footage.

We also process special category data, which is data of a more sensitive nature. Although we do not intentionally collect it, the following special category data may be incidentally captured within drone footage:

  1. Information relating to suspected criminal activity, where individuals are involved in, connected to, or present during an incident.
  2. Visible indicators of special category characteristics, such as religious dress, disability-related features, or racial/ethnic appearance, where these appear naturally within the recorded scene.

We do not collect the following data directly, but it can be inferred from the video imagery captured:

  1. Age (estimated visually)
  2. Gender
  3. Racial or ethnic origin
  4. Physical characteristics or behaviours

No biometric identification, facial recognition, or automated profiling technology is used as part of this drone surveillance system.

WHO WE SHARE YOUR DATA WITH

We only share your personal data where it is necessary, proportionate, and lawful to do so. Your data may be shared with the following parties for the purposes of preventing and detecting crime, protecting people and property, and supporting incident investigations:

  • The Police
    We may provide drone footage or incident-related information to the police where it is required to prevent or investigate a crime, support an ongoing enquiry, or provide evidential material.
  • Businesses on the Team Valley Trading Estate (ASEL Customers)
    If an incident directly affects one of our customers, we may share relevant footage or information with them to support their internal investigations, improve security, or fulfil contractual reporting obligations.
  • Our Technology Supplier (Sorair)
    Sorair may have restricted, controlled access to the system for the purposes of maintaining the drone platform, diagnosing faults, or providing technical support. Sorair only processes personal data under ASEL’s instruction and is contractually prohibited from using it for any other purpose.
  • Insurance Providers or Legal Representatives
    In the event of a claim, legal dispute, or formal investigation, we may share relevant footage with insurers or legal advisors acting on behalf of ASEL or affected customers.

We do not sell your data, share it for marketing purposes, or make it available to any third parties who do not have a lawful basis to receive it. All sharing is governed by strict controls, data-sharing agreements, and audit processes to ensure your data is protected at all times.

RIGHTS OF THE DATA SUBJECT

UK GDPR affords you with a number of rights, your rights are summarised below. ASEL are committed to supporting you with these rights where required and so you may contact our designated Data Protection Officer dpo@asel.co.uk or any employee at any time to exercise these rights.

The right to request access – You have the right to obtain from ASEL free information about your personal data and a copy of the personal data we store (commonly known as a “Subject Access Request”), furthermore you have the right to obtain information as to whether your personal data is transferred to any third countries or international organisations. Where this is the case, you have the right to be informed about any safeguards relating to this transfer.

Right to rectification – You have the right to obtain from ASEL without undue delay the rectification of inaccurate personal data concerning you. Basically, if we hold incorrect data about you, you have the right to have that data corrected.

Right to erasure (right to be forgotten) – UK GDPR grants you the right to have your data deleted when there is no good reason for us to continue to process it. ASEL have an obligation to erase your data without undue delay where one of the statutory grounds applies, as long as the processing is not necessary. ASEL relies on Legitimate Interests as its lawful basis and therefore the processing of your data is necessary to achieve our purpose. For this reason, the right to erasure does not apply in every instance.

Right of Restriction of Processing

You have the right to obtain from ASEL a restriction of processing where a statutory reason applies. This enables you to ask us to suspend processing your data, for example if you want us to establish its accuracy or the reason for processing it.

Right to data portability

You have the right to receive personal data we process concerning you in a structured, commonly used, and machine-readable format. You have the right to request the transfer of your data to another party.

Right to Object

You have the right to object to us processing your personal data, on grounds relating to your situation at any time. This does not mean that we will stop processing your data, but we will review your objection in each case.

Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling.

Right to withdraw consent

ASEL does not use consent as the legal basis for processing, we use legitimate interests for this purpose, therefore you do not have the right to withdraw consent.

Right to complain to the supervisory authority

The contact details for the ICO are contained in this privacy notice.

HOW TO EXERCISE YOUR RIGHTS

You will not usually pay a fee to access your personal data or to exercise any of your other rights. We may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. If you wish to exercise your rights, then please contact us at dpo@asel.co.uk.

WHAT IS OUR LEGAL BASIS?

ASEL uses the lawful basis “legitimate interests” for processing your data as the processing is necessary to protect the business interests of our customers and there is no less intrusive method to achieve those business interests with the same level of impact. Our legitimate Interest is not outweighed by the rights and freedoms of the affected data subjects as our processing is in the substantial public interest and for the benefit of ASEL, its customers, customer consumers, and subjects of interest.

ASEL has conducted a Legitimate Interests Assessment which is available on request.

Where we incidentally process Special Category Data through our drone surveillance operations, we do so on the basis that the processing is necessary for reasons of substantial public interest, in accordance with Article 9(2)(g) of the UK GDPR. We have assessed this interest against the relevant provisions of the Data Protection Act 2018 (DPA 2018) and determined that the processing is necessary for the purpose of preventing or detecting an unlawful act, in accordance with paragraph 10, Schedule 1, Part 2 of the DPA 2018.

We also recognise that we process criminal offence data, as defined under Article 10 of the UK GDPR and further described in ICO guidance. This may include footage or information relating to suspected criminal activity captured during drone operations. The condition we rely upon for processing criminal offence data under the Data Protection Act 2018 is the same as for Special Category Data: the prevention or detection of unlawful acts, as set out in paragraph 10 of Schedule 1, Part 2 of the DPA 2018.

ASEL has conducted a Data Protection Impact Assessment (DPIA) for its aerial drone services, which is reviewed annually and upon significant changes to our processing activities.

PERSONAL DATA AND RETENTION PERIODS

All personal data is held in UK based secure servers. Data processed within our software will be held for 30 days before it is permanently and securely disposed of. The secure disposal of your data is an automatic process removing the risk of human error.

In certain circumstances, we may need to retain specific footage for longer than 30 days. This will only occur where the footage is required for the prevention or detection of crime, to support an active investigation, to respond to a legal request, to support insurance or evidential needs, or where retention is necessary to establish, exercise, or defend legal claims. In these cases, access to the retained footage is strictly limited, and it will be securely deleted as soon as it is no longer required for these purposes.

SECURITY OF PROCESSING

As the Data Controller ASEL have implemented appropriate technical and organisational measures to ensure your Personal Data always remains secure.

HOW TO CONTACT THE ICO

You have the right to lodge a complaint with the supervisory authority if you believe we are infringing UK data protection laws or you are concerned about the way in which we are handling your personal data, in the case of the UK this is the ICO.

You can contact the ICO by following this link https://ico.org.uk/global/contact-us/ or by telephone on 03031231113.

CHANGES TO THIS NOTICE

This notice was last updated on 13/07/202. We may change this notice by updating this page to reflect changes in the law or our privacy practices at any time.

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