ASEL Privacy Notice

INTRODUCTION

Argenbright Security UK Limited (“ASEL”) is a private security company that supports a number of UK retailers, wholesalers, transport and distribution companies.

ASEL is authorised by its customers to perform security and loss prevention duties across their estates.

ASEL gathers information from its Customers, its Security Officers and key Partners such as the National Business Crime Solution Limited on ‘Subjects of Interest’ (“SOI”), and stores it in a number of software platforms including its own software, when necessary, and in order to prevent crime, shares it’s intelligence with Customers, its Security Officers and the Police. In particular, ASEL collects information from its Customers, Security Officers and Partners about individuals who:

  • Have committed criminal offences or attempted to commit offences against its Customers or their employees including violence and/or
  • Have exhibited anti-social behaviour, within or around a Customers premises or property.
    The information collected contains Personal Data which may include data relating to suspected offences.
    Once received from a Customer, a Security Officer, a Partner, or the Police, ASEL stores the information in its secure software, and shares certain elements of it with other Security Officers, Customers and the Police when this is justified, proportionate, necessary and fair and lawful to do so.

 

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 persons sexual orientation.

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 Client

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
Stanley House
Station Approach
London Road
Great Chesterford
Safron Walden
Essex
England
CB10 1NY

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 is contracted by its customers to protect life, protect property and premises, prevent crime including violence and threats of violence and prevent loss and waste.

We do this by detecting crime or suspicious behaviour, preventing crime and apprehending individuals who commit crime against our customers or security officers.

Some examples of how ASEL is able to achieve this are set out below:

ASEL is able to collate and link offence data provided by individual ASEL Customers and our security officers. This means offence data can be collated and provided to the Police or our Partner organisations such as the National Business Crime Solution Ltd as series linked investigations, making it more likely that an offender will be apprehended through police action. Such reporting makes eventual apprehension much more likely than individual reporting of crimes to the police by ASEL Customers.

ASEL Customers, and Security Officers are more likely to report known or suspected offenders to ASEL than to the police. ASEL is able use such offence data provided by its Customers to identify and analyse trends and generate reports and analysis. This in turn helps ASEL, the Police and the Customer develop better strategies for dealing with crime.

ASEL can identify prolific and persistent offenders targeting multiple businesses and can assist its Security Officers and Customers in serving exclusion notices against these individuals removing their implied right to enter those businesses or private property such as in customer stores or on retail parks.

This in turn reduces the likelihood that those individuals will re-enter those business premises and property and commit further crime. Additionally, should that individual breach the exclusion notices then the ASEL can support that Customer, or a group of Customers in applying for a civil court injunction or support Police in obtaining Criminal Behaviour Orders. This action further prevents the individual entering the Customer premises and if breached can constitute contempt of court.

By sharing proportionate actionable intelligence with its Security Officers and Customers, ASEL can support Customer and Security Officer target hardening, thereby reducing crime and the risk of crime and anti-social behaviour within their stores, premises, or property.

By conducting their work, ASEL wish to achieve a reduction in criminal activity within the retail and distribution sector and create a safer experience for both their employee’s and consumers. ASEL is already demonstrating achievements as highlighted above, and, therefore, with the support of all interested parties including the Police needs to continue with this work.

 

WHAT DATA DO WE COLLECT AND PROCESS

In order to achieve our purpose, we may collect the following data:

  • Name and address details
  • Images taken from CCTV
  • Video taken from CCTV
  • Images taken from Body Worn Video
  • Images taken from CCTV for the purpose of live facial recognition supporting identification of offenders or suspected offenders
  • Images taken from Body Worn Video for the purpose of live facial recognition supporting identification of offenders or suspected offenders
  • Date of birth, age and descriptive details such as tattoos, facial hair, eye colour, hair colour, height, build clothing , piercings, glasses and other identifiable features.
  • Gender
  • Email address
  • Phone number
  • Details of associates
  • Vehicle Registration Details for the purpose of automatic number plate recognition
  • Any records of correspondence

We may also process special category data, which is data of a more sensitive nature, the following data types may apply:

  • Race and or ethnic origin
  • Details of suspected criminal offences
  • Details of civil action taken against individuals

 

FACIAL RECOGNITION

The ASEL facial recognition system uses facial recognition technology to identify subjects of interest who we have good reason to believe have committed an offence against one of our Customers or Security Officers.

Images are collected by our Security Officers during their tour of duty of individuals who have or are highly likely to have committed an offence against our Customer or our Security Officer. Our Command and Intelligence Centre link the subject’s image to an incident report and complete thorough and robust checks to ensure the accuracy of the data. Our Command and Intelligence Centre analysts then upload the subject image onto our facial recognition platform if it meets our robust criteria.

Following a match our software will alert the security officer that there is a high likelihood that the image matches a subject of interest.

Before any action is taken against the subject of interest the security officer must confirm the image identified matches the subject. There is therefore human intervention at every stage of this process and no decisions which may impact the data subject are made on an automated basis.

ASEL has robust processes and training in place to ensure this process is followed each time a potential match is identified.

In order for facial recognition to be successful we must process data on subjects of interest, and members of the public. When you interact with our security officer your image will be taken by the software and compared to the ASEL watch list. If there is no match against the database then your image is immediately and irrecoverably deleted, this happens in an instant meaning there is no risk to data subjects who are not subjects of interest.

We consider this process to be less intrusive than store CCTV, store CCTV captures your data and stores it for 30 days, often on internal store hard disks.

 

AUTOMATIC NUMBER PLATE RECOGNITION

The ASEL automatic number plate recognition system uses technology to identify vehicles which we believe have been involved in crime against our customers. Vehicle Registration Numbers are collected by ASEL both directly and indirectly from third party Data Controllers and stored in our ANPR software.

Following a vehicle match our software will alert our Command and Intelligence Centre team who will double check the vehicle against the vehicle in our database and ensure the match is correct. There is therefore human intervention at every stage of this process and no decisions which may impact the data subject are made on an automated basis.

Our Command and Intelligence centre will then confirm with our security officers who will take preventative action against the data subject. We may also make our customers aware of the match to enable our customers to prevent any potential crimes against their business.

Third party organisations we work with to support our ANPR operations are:

National Business Crime Solution Ltd, their Data Protection Officer can be contacted at the following email address – enquiries@nationalbusinesscrimesolution.com.

 

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. Our legitimate Interest is not outweighed by the rights and freedoms of the affected data subjects as our processing is for the substantial public interest, the benefit of ASEL, its customers and consumers.
Where we process Special Category Data, such as biometric data for the purpose of live facial recognition, we do so on the basis that it is necessary for the substantial public interest, in accordance with Article 9 (2) (g) of the UK GDPR. We have assessed this interest against the appropriate provisions within the Data Protection Act 2018 (DPA 2018) and considered that our processing is necessary for the provision of detecting an unlawful act, in accordance with paragraph 10, schedule 1 of Part 2 of the DPA 20218.

 

PERSONAL DATA AND RETENTION PERIODS

Most of your personal data will be held for 25 months before it is permanently and securely disposed of. The secure disposal of your data is an automatic process removing the risk of human error. All personal data is held in UK based secure servers.

Your biometric data used for live facial recognition will be disposed of after 12 months.

Your vehicle registration mark data will be disposed of after 3 months.

Your images held on body worn video for the protection of our security officers will be disposed of after 30 days.

 

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 01/09/2023. We may change this notice by updating this page to reflect changes in the law or our privacy practices at any time.