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Privacy Policy

    • I. Proper Handling of the Recorded Images

      (a) The personal data collected is securely deleted from the CCTV as soon as practicable once the purpose of collection is fulfilled. If no incident is reported, the footage will be securely deleted regularly accordingly.

      (b) Upon expiry of the applicable retention period, we permanently destroy all personal data: (i) if in hard copy form, by first shredding and then securely disposing of the personal data; and (ii) if in electronic form, by permanently erasing the personal data from our systems. The CCTV footage/images are removed automatically from the system regularly. All authorized users having access to any copy pf the CCTV footage/images shall delete such copy once any reported incident being reported is closed or is no longer active.

      (c) If an incident occurs in the store, CCTV footage is preserved in a secure way until such time as the incident is fully investigated and the matter is closed. Usual deletion policies in relation to CCTV footage are suspended for the relevant footage during that period.

      (d) Security measures are in place to prevent unauthorized access to the CCTV system. Recorded images are kept in safe custody, subject to and in accordance with the following measures:

      (1) A login account and password for access to and storage of footages is available only to authorized users.

      (2) Access to locations where the images recorded by the CCTV cameras are viewed, stored or handled are secured and restricted to authorized users only. The authorized users can only view the CCTV footage only when the incident is reported.

      (3) CCTV footage is not transferred in digital format through email, mobile or any other device other than to the Legal Department or to authorized users provided that the footage is encrypted and then only as strictly necessary for valid reason and subject to and in accordance with this clause and clause II below.

      (e) Proper records of the staff members taking charge of and keeping the recorded images are maintained by authorized users.

      (f) Transfer and movements of the recorded images are clearly documented and only made in accordance with clause I(d)(3).

      (g) The hard disks or any devices storing the recorded images are securely protected from unauthorized access (e.g. an encryption function is used) and only viewed, retrieved or handled upon proper authorization for the intended purpose (e.g. police investigation). Once there is no valid reason to retain the recorded images, they are securely deleted. Safeguards are in place to protect wireless transmission systems from interception should they be used for transmission of data recorded by CCTV.


      II. Transfer of CCTV Records to Third Parties

      (a) Personal data is only used for the purposes for which it was collected or a directly related purpose (see How do we use this information, and what is the legal basis for this use? section above, unless the data subject has given their express voluntary consent for any other purpose or when any applicable exemptions under the Ordinance apply.

      (b) Disclosure of CCTV records to any third party shall only be in accordance with section Who will we share this data with, where and when? or in accordance with the Ordinance.

      (c) If we are requested to provide CCTV records to a law enforcement agency e.g. the Police for criminal investigation purposes, we will cooperate only with a written request provided by the relevant law enforcement agency and if we reasonably believe that an exemption under the Ordinance applies.


      III. Misuse or abuse of CCTV system or the recorded images is reported to Privacy Officer at (email: privacyofficer@lanecrawford.com; Telephone: +852 2118 2280).


      IV. Compliance checks and audits are carried out annually to review the effectiveness of the safeguards and procedures of the CCTV system.



I. Proper Handling of the Recorded Images

(a) The personal data collected is securely deleted from the CCTV as soon as practicable once the purpose of collection is fulfilled. If no incident is reported, the footage will be securely deleted regularly accordingly.

(b) Upon expiry of the applicable retention period, we permanently destroy all personal data: (i) if in hard copy form, by first shredding and then securely disposing of the personal data; and (ii) if in electronic form, by permanently erasing the personal data from our systems. The CCTV footage/images are removed automatically from the system regularly. All authorized users having access to any copy pf the CCTV footage/images shall delete such copy once any reported incident being reported is closed or is no longer active.

(c) If an incident occurs in the store, CCTV footage is preserved in a secure way until such time as the incident is fully investigated and the matter is closed. Usual deletion policies in relation to CCTV footage are suspended for the relevant footage during that period.

(d) Security measures are in place to prevent unauthorized access to the CCTV system. Recorded images are kept in safe custody, subject to and in accordance with the following measures:

(1) A login account and password for access to and storage of footages is available only to authorized users.

(2) Access to locations where the images recorded by the CCTV cameras are viewed, stored or handled are secured and restricted to authorized users only. The authorized users can only view the CCTV footage only when the incident is reported.

(3) CCTV footage is not transferred in digital format through email, mobile or any other device other than to the Legal Department or to authorized users provided that the footage is encrypted and then only as strictly necessary for valid reason and subject to and in accordance with this clause and clause II below.

(e) Proper records of the staff members taking charge of and keeping the recorded images are maintained by authorized users.

(f) Transfer and movements of the recorded images are clearly documented and only made in accordance with clause I(d)(3).

(g) The hard disks or any devices storing the recorded images are securely protected from unauthorized access (e.g. an encryption function is used) and only viewed, retrieved or handled upon proper authorization for the intended purpose (e.g. police investigation). Once there is no valid reason to retain the recorded images, they are securely deleted. Safeguards are in place to protect wireless transmission systems from interception should they be used for transmission of data recorded by CCTV.


II. Transfer of CCTV Records to Third Parties

(a) Personal data is only used for the purposes for which it was collected or a directly related purpose (see How do we use this information, and what is the legal basis for this use? section above, unless the data subject has given their express voluntary consent for any other purpose or when any applicable exemptions under the Ordinance apply.

(b) Disclosure of CCTV records to any third party shall only be in accordance with section Who will we share this data with, where and when? or in accordance with the Ordinance.

(c) If we are requested to provide CCTV records to a law enforcement agency e.g. the Police for criminal investigation purposes, we will cooperate only with a written request provided by the relevant law enforcement agency and if we reasonably believe that an exemption under the Ordinance applies.


III. Misuse or abuse of CCTV system or the recorded images is reported to Privacy Officer at (email: privacyofficer@lanecrawford.com; Telephone: +852 2118 2280).


IV. Compliance checks and audits are carried out annually to review the effectiveness of the safeguards and procedures of the CCTV system.