CCTV Privacy Notice

1. General Statement

MI TECHNOLOGIES PHILIPPINES CORPORATION (“Xiaomi”) believes that CCTV and other surveillance systems (collectively as “CCTV Systems”) have a legitimate role to play in helping to maintain a safe and secure environment for all its staff and visitors. However, Xiaomi recognizes that this may raise concerns about the effect on individuals and their privacy. This policy is intended to address such concerns. Images recorded by CCTV systems may include personal data which must be processed in accordance with Guidelines on the Circular on CCTV systems issued by the National Privacy Commission (NPC Circular No. 2024 – 02) and other related data protection laws of the Republic of Philippines. Xiaomi is committed to complying with its legal obligations and ensuring that the legal rights of data subjects, relating to their personal data, are recognized and respected.

2. Purpose and legal basis of the CCTV System

We use CCTV Systems to record images to assist in the provision of a safe and secure environment for the benefit of those who work at and visit Xiaomi’s premises, and for the protection of our property. Our CCTV Systems are used for the following purposes:

  • maintain public safety in our premises;

  • maintain the security of our property;

  • assist in the prevention of crime;

  • facilitate the apprehension and prosecution of offenders in relation to crimes occurring within our premises;

  • supply footage to law enforcement agencies as required by the law;

  • assist in administrative investigation if requested to do so and the requesting party shall provide sufficient proof of such investigation.

We consider the processing of personal data for these purposes to be in our legitimate interests.

3. Operational details of the CCTV System.

We use the CCTV system provided by CLOSED-EYED CCTV INSTALLER AND REPAIR SERVICES.

  • The storage capacity is 24T;

  • The CCTV camera will only record image and will not record the sound;

  • 24 CCTV cameras are in operation 24 hours a day from 00:00 to 23:59;

  • CCTV cameras are located at the HALLWAY, MEETING ROOMS, ENTRY AND EXIT POINT, RECEPTION, AND SERVER AREA.

4. Access and Disclosure

4.1 Control of Access

Staff access to our CCTV Systems and CCTV footage is strictly controlled and is limited to those who need to have such access in accordance with this policy.

Disclosure of CCTV footage will only be provided to third parties for the purposes outlined above and in compliance with applicable laws.

4.2 Access purpose

Live or recorded CCTV footage may only be viewed for the following purposes mentioned in section 2. The CCTV footage may be used by us after an incident to assist in the identification and detection of offenders or in the investigation of a security incident.

4.3 Disclosure to Third-parties

Third-parties should not require or be provided with CCTV footage except under the following circumstances:

  • Law enforcement and criminal investigations.

  • Court Order.

  • Administrative investigations.

  • Request from the media. The disclosure should always be with due regard to the general principles of privacy, rights of data subjects, and codes of conduct and ethical standards of journalism. Xiaomi will not disclose CCTV footages of identifiable individuals to the media for amusement or entertainment purposes, unless it is with the consent of the data subjects or otherwise permitted under the applicable laws.

  • Other third-party requests. Third-party access requests for CCTV footage and images shall be evaluated with greater scrutiny to prevent violation of the privacy rights of the data subjects concerned. Xiaomi will determine these requests on a case-to-case basis and only release the CCTV footage and images to third parties when our determination shows that the requesting third party’s needs outweigh those of the data subjects to whom the CCTV footage and images pertain.

5. Retention policy

Recordings of footage from our CCTV cameras will be kept in HARD DISK DRIVES, which are used to store recordings for maximum of 20 days after which time all recordings will be permanently deleted. Our HARD DISK DRIVEs are located in the head office of Xiaomi in the Philippines.

Footage maybe retained for longer than 20 days if it has been requested by the relevant authorities as evidence for part of a criminal investigation or for staff improvement and or disciplinary investigations.

We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure.

6. Your Data Protection Rights.

The privacy laws of the Republic of Philippines give data subjects the right to access, amend, or delete their personal information or, in some circumstances, to restrict or object the processing of their personal information.

  • Right to access. If you would like to access the CCTV footage or request a copy of all or any part of the data we hold about you, please contact us via the contact information set below. For request for reviewing only, your request will be processed within 5 working days. For requests that involves obtaining a copy, your request will be processed within 15 working days from the date we receive your request. We may refuse your request following our legal rights or court orders, and where your request for access or copy of the CCTV Data conflicts with the right of others. We will inform you about the reasons if your request is rejected.

  • Right to object. You have the right to object to the collection, use, or disclosure of your CCTV Data if it is for the purpose of achieving our legitimate interest and/or that of other persons. Your request will be processed within 7 working days upon our receiving your request. We may refuse your request if we can prove that there is more important legal interest to collect, use, or disclose your CCTV Data, or such collection, use, or disclosure is for establishing claims, performing, defending or exercising legal claims, or complying with the laws.

  • Right to withdraw your consent. For the purposes you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time.

  • Right to erase. You have the right to request us to delete your CCTV Data or to render your CCTV Data to be unidentifiable to the extent applicable under the laws, except for cases where we may need to collect your CCTV Data as applicable under the law, such as establishing claims, performing, defending or exercising legal claims, or complying with the law.

  • Under the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission [https://privacy.gov.ph/wp-content/uploads/2024/08/NPC-Circular-No.-2024-02-CCTV-Systems.pdf].

7. Security Measures

 All CCTV footage shall be held securely and shall be accessible only by our employees with requisite access rights.

We will take all reasonable precautions necessary to protect CCTV footage from:

  • misuse, interference and loss; and

  • unauthorized access, modification or disclosure.

8. Contact and further information

If you have any concerns about our data processing practice outlined in this Privacy Policy, wish to exercise your rights as a data subject or submit a written complaint about how we handle your personal information, please contact https://privacy.mi.com/support/?locale=en to submit your concerns. We will be happy to resolve your concerns directly.

 

Date of version: 30 September 2024