CCTV Privacy Notice Policy
Ramkhamhaeng 2 Hospital
1. Objective
We collect personal data through the use of Closed-Circuit Television (CCTV) for the following purposes:
1.1 To protect your health and personal safety, including the protection of your property.
1.2 To protect our buildings, facilities, and property against damage, disruption, destruction, or other criminal activities.
1.3 To support relevant authorities in law enforcement activities, including deterrence, prevention, investigation, and legal proceedings.
1.4 To assist in the resolution of disputes arising during disciplinary or grievance procedures.
1.5 To assist in investigations or processes relating to the submission and handling of complaints.
1.6 To assist in initiating or defending civil claims, including, but not limited to, legal proceedings relating to employment.
2. Policy
This CCTV Privacy Notice (“Notice”) provides information regarding the collection, use, and disclosure of personal data that may identify you, as well as the legal bases for processing your personal data. We collect and process your personal data based on the following legal bases:
2.1 The necessity to prevent or suppress danger to the life, body, or health of you or another person.
2.2 The necessity for our legitimate interests or those of another person, provided that such interests are not overridden by your fundamental rights in relation to your personal data.
2.3 The necessity to comply with applicable laws and regulations relating to the safety and security of the workplace environment and the Hospital's property.
3. Scope
The Hospital collects, uses, or discloses personal data through the use of CCTV equipment installed within and around the premises of Ramkhamhaeng 2 Hospital.
4. Definitions
4.1 “Security Department” or “we” means the Security Department under the Service Support Division of the Hospital.
4.2 “Premises” means the areas within and surrounding the Hospital.
4.3 “You” means officers, personnel, customers, employees, contractors, visitors, or any other persons entering the Premises where CCTV equipment is in operation.
4.4 “Personal Data” means any information relating to an individual that enables such individual to be identified, whether directly or indirectly.
5. Responsible Departments
Security Department, Service Support Division, and Information Technology Department of the Hospital
6. Procedures
6.1 Personal Data We Collect and Use
As stated in the purposes above, we install CCTV cameras in visible locations and place CCTV warning signs at entrances and exits, as well as in other areas where we consider surveillance necessary. When you enter the Premises, the CCTV system may collect the following personal data:
1) Still images
2) Moving images or video recordings
3) Audio recordings
4) Images of your property, such as vehicles, bags, hats, clothing, and other personal belongings.
We will not install CCTV cameras in areas where surveillance may disproportionately infringe upon your fundamental rights, including bedrooms, toilets, bathrooms, or designated rest areas for personnel.
6.2 Disclosure of Your Personal Data
We will keep CCTV footage relating to you confidential and will not disclose such information except where disclosure is necessary to achieve the surveillance purposes specified in this Notice. We may disclose CCTV footage to the following categories of persons or entities:
1) Competent authorities as required or permitted by law, in order to assist and support law enforcement, investigations, inquiries, or legal proceedings.
2) Third-party service providers, where necessary to ensure the prevention or suppression of danger to the life, body, health, or property of you or another person.
6.3 Your Rights under the Personal Data Protection Act B.E. 2562 (2019)
The Personal Data Protection Act B.E. 2562 (2019) is intended to provide data subjects with greater control over their personal data. You may exercise your rights under the Personal Data Protection Act B.E. 2562 (2019), subject to the applicable provisions and conditions of the law, including the following:
1) Right of Access: You have the right to access and obtain a copy of your personal data collected by us and to request information regarding the source of such personal data, except where we are legally entitled to refuse your request, such as where required by law or a court order, or where fulfilling the request may adversely affect the rights and freedoms of another person.
2) Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data to ensure that your personal data is accurate, current, complete, and not misleading.
3) Right to Restriction of Processing: You have the right to request the restriction of the use of your personal data in any of the following circumstances:
(1) While we are verifying your request to correct your personal data so that it is accurate, complete, and up to date.
(2) Where your personal data has been unlawfully collected, used, or disclosed.
(3) Where your personal data is no longer necessary for the purposes for which it was collected, but you request that we retain the data for the establishment, exercise, or defense of your legal claims.
(4) While we are verifying whether we have legitimate grounds for collecting, using, or disclosing your personal data, or determining whether the processing is necessary for the performance of a task carried out in the public interest, following your exercise of the right to object to the collection, use, or disclosure of your personal data.
4) Right to Object: You have the right to object to the collection, use, or disclosure of your personal data, except where we have lawful grounds to refuse your request, such as where we can demonstrate compelling legitimate grounds for the collection, use, or disclosure of your personal data, or where the processing is necessary for the establishment, exercise, or defense of legal claims, compliance with legal obligations, or the performance of a task carried out in the public interest.
6.4 Retention Period of Personal Data
For the purposes of CCTV surveillance as specified in this Notice, we will retain CCTV footage relating to you for a period of 1 month from the date on which the Security Officer has completed the relevant retrospective review, or for as long as necessary to achieve the purposes specified in this Notice. The personal data may be retained for a longer period where required by applicable laws or regulations or where necessary for the establishment, exercise, or defense of legal claims. Upon expiration of the applicable retention period, we will delete, destroy, or otherwise securely dispose of your personal data in accordance with applicable laws and our data retention procedures.
6.5 Personal Data Security
We implement appropriate technical and organizational measures to protect your personal data against loss, unauthorized access, deletion, destruction, use, alteration, modification, or disclosure. These measures are implemented in accordance with our Information Security Policy and related information security practices. In addition, we have established a Personal Data Protection Policy that has been communicated throughout the organization, together with appropriate procedures and practices to ensure the security of personal data during its collection, use, and disclosure. We maintain the following fundamental principles of information security:
- Confidentiality – ensuring that personal data is accessible only to authorized persons.
- Integrity – ensuring that personal data remains accurate, complete, and protected against unauthorized alteration.
- Availability – ensuring that personal data is available to authorized persons when required.
We will periodically review this policy and this Notice at an appropriate interval to ensure that they remain suitable and effective.
6.6 Responsibilities of the Data Controller
We have restricted access to personal data to authorized personnel whose duties and responsibilities are directly related to the collection, use, or disclosure of personal data under this processing activity. Such personnel are required to strictly comply with this Notice and applicable personal data protection and information security policies.
6.7 Changes to This Privacy Notice
We may revise or amend this Notice from time to time as we deem appropriate. Any changes will be communicated through the QR Code displayed at the Hospital entrances, Security Guard Posts, and Information/Reception Desks. The effective date of the latest version of this Notice will be indicated at the end of the Notice. We recommend that you regularly review the latest version of this Notice, particularly before entering our Premises. By entering the Premises, you acknowledge this Notice. If you do not agree with the terms of this Notice, please refrain from entering the Premises. If you continue to enter the Premises after this Notice has been amended and published through the channels specified above, you will be deemed to have acknowledged the relevant changes.
6.8 Contact Information
If you have any questions or require further information regarding this Notice, please contact:
Ramkhamhaeng 2 Hospital
222 Ramkhamhaeng Road, Rat Phatthana Subdistrict, Saphan Sung District, Bangkok 10240, Thailand
Telephone: 02-032-3888
An example of a CCTV Notice Sign to be displayed in areas where CCTV cameras are installed, in order to inform data subjects before entering the monitored area.
7. Process Monitoring and Measurement
None
8. References
8.1 Personal Data Protection Act B.E. 2562 (2019)