1. Introduction
1.1 Behaviour Interactive Inc. and its affiliates (“BHVR”), having its principal place of business at 500-6666 Saint-Urbain Street, Montreal, Quebec, Canada, has implemented a camera surveillance system (“CCTV System”) in its Offices (as defined below). The images of individuals captured by the CCTV System are personal data under privacy legislation (the “Images”).
1.2 This Policy sets out the accepted use and management of the CCTV System at the Codeglue B.V. and Behaviour Interactive UK Limited offices (“Offices”) and details the steps BHVR has taken to ensure compliance with applicable privacy legislation, including the General Data Protection Regulation (“GDPR”), the UK GDPR, and the UK Data Protection Act 2018.
2. Camera Surveillance System Overview
2.1 BHVR is the controller of the CCTV System in the Offices.
2.2 Signs are placed at all entrances to the Offices so that staff and visitors are aware of the CCTV System.
2.3 The legal basis permitting BHVR to process the CCTV Images is BHVR’s legitimate interests, including safeguarding its property and protecting its employees and other individuals on the premises.
3. Purposes of the Camera Surveillance System
3.1 The purposes of BHVR’s CCTV System are as follows:
3.1.1 For the prevention, detection and investigation of crime and other incidents, including theft;
3.1.2 To ensure the safety of staff and visitors; and
3.1.3 To assist in the investigation of suspected illegal or prohibited activities.
4. Monitoring and Recording
4.1 The CCTV System is operational:
4.1.1 at the entrance of the Offices, 24 hours a day, every day of the year; and
4.1.2 within the public areas of the Offices, outside of regular working hours (from 5pm to 9am), every day of the year.
4.2 BHVR’s Information Technology department is responsible for the management and operation of the CCTV System, including activities relating to installations, recording, reviewing, monitoring, and ensuring compliance with this Policy.
4.3 Access to the CCTV System will be limited to personnel on a need to know/access basis for the purposes outlined in this Policy.
4.4 The Images are recorded on servers located securely in the Montreal office.
4.5 The cameras installed provide Images that are of sufficient quality for the purposes outlined in this Policy. The CCTV System will be periodically checked to ensure the quality of the Images remains suitable.
5. Retention of Images
5.1 Unless the CCTV Images are required for evidentiary purposes, the investigation of illegal or prohibited activity or as required by law (an “Incident”), the Images will be retained for 6 weeks from the date of recording, after which they will be deleted.
5.2 In the event of an Incident, the Images will be retained until the Incident is resolved.
6. Data Subject Requests
6.1 Under certain circumstances, data subjects have rights under applicable data protection laws in relation to their personal data, such as:
6.1.1 Request access to your personal data;
6.1.2 Request correction of your personal data;
6.1.3 Request erasure of your personal data;
6.1.4 Object to processing of your personal data;
6.1.5 Request restriction of processing your personal data;
6.1.6 Request transfer of your personal data.
6.2 In order to locate the requested Images of the CCTV System, sufficient detail must be provided by the data subject to allow the relevant Images to be located and the data subject to be identified.
6.3 Further details on privacy requests can be found in the Employee Privacy Policy.
6.4 If you have any questions or complaints regarding this Policy or if you want to exercise your legal rights or appeal any adverse decisions made by us regarding BHVR’s use of its CCTV System, please contact us:
6.4.1 by email: legal@bhvr.com; or
6.4.2 by mail: Attn: Legal Department, Behaviour Interactive Inc., 500-6666 Saint-Urbain Street, Montreal, Quebec H2S 3H1, Canada.
7. Monitoring Compliance
7.1 All staff involved in the operation of BHVR’s CCTV System will only be authorized to use the CCTV System in a way that is consistent with the purposes and procedure outlined in this Policy.
8. Changes and Derogation
8.1 This Policy may be updated from time to time, in which case the changes will be posted on this page, and where appropriate, notified to you through signage or other means.
8.2 Any derogation to this Policy must be approved in writing by the Legal Department.
