Towns and City Centres Privacy Notice

INTRODUCTION

Argenbright Security Europe Limited (“ASEL”) is a private security company that supports a number of UK urban centres such as town and city centre areas. We support these areas by working with the local Business Improvement District and or Local Authority.

ASEL is authorised by its customers to perform security and loss prevention duties across these urban centres. ASEL is also supported by local police forces in terms of delivering the objectives of the Business Improvement District or local authority.

ASEL gathers information from local businesses, its Street teams and key partners such as the National Business Crime Solution Limited and local policing 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 local businesses, its Street teams and the Police. ASEL collects information from local businesses, Street teams and Partners about individuals who:

  • Have committed criminal offences or attempted to commit offences within the town or city centre or against local businesses or their employees including violence and/or
  • Have exhibited anti-social behaviour, within or around a local business or within the city or town centre.
  • Have committed public order offences or attempted to commit public order offences within or around the city or town area or against a local business.

The information collected contains Personal Data which may include data relating to suspected offences.

Once received from a local business, a Security Officer, a Partner, or the Police, ASEL stores the information in its secure software, and shares certain elements of it with other ASEL security officers, local businesses 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 – City Centre Business or Business Improvement District

Partners – Organisations with which we may share your data.

SOI – Subjects of Interest are individuals who are suspected of or have committed crime against the town or city centre, local businesses or their colleagues or street teams.

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 is contracted by the Business Improvement District or Local Authority 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 local businesses, the town or city centre or our street teams.

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 local businesses and our street teams. 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 local businesses within the town or city centre.

Local businesses, and our street teams are more likely to report known or suspected offenders to ASEL than to the police. ASEL is able use such offence data provided by local businesses to identify and analyse trends and generate reports and analysis. This in turn helps ASEL, the Police and the Business Improvement District or Local Authority develop better strategies for dealing with crime.

ASEL can identify prolific and persistent offenders targeting multiple businesses and can assist its street teams local businesses and police in serving exclusion notices against these individuals removing their implied right to enter local businesses.

This in turn reduces the likelihood that those individuals will re-enter those business premises and property and commit further crime. It also reduces the likelihood that those individuals will continue to commit crime in the town or city centre. Additionally, should that individual continue to commit crime or antisocial behaviour then ASEL can support Police in obtaining Criminal Behaviour Orders or Public Space Protection Orders. This action further prevents the individual committing crime or antisocial behaviour in the town or city centre or against local businesses.

By sharing proportionate actionable intelligence with its Street teams and local businesses, ASEL can support local business and Security Officer target hardening, thereby reducing crime and the risk of crime and anti-social behaviour within their stores and the local area.

By conducting their work, ASEL wish to achieve a reduction in criminal activity within the town or city centre and create a safer experience for visitors to the area, shoppers and local businesses and their colleagues. 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.

Specifically the data will be processed to achieve the following:

  • the capture of evidence against offenders or suspected offenders to support criminal behaviour orders, public space protection orders and prosecution where appropriate.
  • the delivery of improved outcomes for BID levy payers and visitors to the BID area including a reduction in crime, including violence and antisocial behaviour against workers and visitors
  • the delivery of improved outcomes for BID levy payers including a reduction in external shrinkage from theft and other offences
  • the protection of the public and reduction of antisocial behaviour and violence against levy payer workers, consumers and the wider public
  • improved personal safety for ASEL Street Teams while on duty.

WHAT DATA DO WE COLLECT AND PROCESS

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

  1. Name and address details
  2. Images taken from CCTV
  3. Video taken from CCTV
  4. Images taken from Body Worn Video
  5. Video taken from Body Worn Video
  6. 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.
  7. Gender
  8. Email address
  9. Phone number
  10. Details of associates
  11. Vehicle Registration Details
  12. 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:

  1. Details of suspected criminal offences
  2. Details of civil action taken against individuals

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 LAWFUL BASIS?

ASEL uses the lawful basis ‘legitimate interests’ for processing your data as the processing is necessary to protect the business interests of local business and town or city centre visitors 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, Business Improvement Districts and consumers.

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.

Video and images captured on Body Worn Video will be stored for 30 days on our secure Digital Evidence Management System and then deleted automatically by the software. Some data may be processed for longer periods should it be used to support CBO application etc or used to support criminal investigations.

SECURITY OF PROCESSING

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 13/07/2026. 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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