South Asia Law Co., Ltd. ("we", "us", "our" or the “Company”) uses CCTV cameras to monitor and record certain area of the premises of the Company for the purpose of protecting Company property and as such, individuals in the premises would be recorded by the CCTV. We have established and disclose this CCTV Privacy Notice to explain how we collect, use or disclose your personal data, and how we protect personal data and properly handle such information according to the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”).

SCOPE OF THE CCTV PRIVACY NOTICE

This CCTV Privacy Notice covers these topics:

• Purposes of collection, use or disclosure of personal data
• Types of personal data we collected
• Disclosure of your personal data
• Retention period of personal data
• Your rights
• Security measures of your personal data

1. Purposes of collection, use or disclosure of personal data

Any collection or use of your personal data by relevant employees of the Company or other relevant persons or any actions performed on behalf of the Company which is necessary for controlling and monitoring the security of the premises of the Company, including the use of personal data and purposes for any undertakings may rely on (1) the basis of Legitimate Interest; and (2) the basis of Legal Obligation, as follows:

 1.1 To control access to the premises, and to observe, prevent, deter, and (if necessary) investigate unauthorized access to the premises for the purpose of            monitoring the security and safety of the Company’s premises;

 1.2 To control access to information technology resources and database of the Company;

 1.3 To maintain data from CCTV in the Company’s database, including to monitor and examine the CCTV system for the above purposes;

 1.4 To use as evidence in order to proceed with any legal actions including taking necessary legal proceedings or complying with an order of a court, or any          competent authorities; and

In the case where the Company needs to collect, use, disclose or perform any processing with your personal data, apart from the purposes mentioned in this Privacy Notice, the Company will notify of such change on www.southasia-law.com.

2. Types of personal data we collected

We collect images caught on CCTV cameras which may include still images and video images, and no voice is recorded.

3. Disclosure of your personal data

We will not disclose your personal data collected through the CCTV system as mentioned above to third parties. However, we may disclose your personal data to a third party only as permissible by law.

4. Retention period of personal data

We retain your personal data for no more than 90 days after your visit to our premises or until the expiration of the statutory period. After the expiration of such period, any images recorded by the CCTV are automatically deleted.

5. Your rights

You are entitled to the following rights under the PDPA:

 5.1 Right of access

 You have the right to request access and to obtain a copy of your personal data, limited to those which you have  consented to the Company, and which is  held by the Company, or to request disclosure of the source which your  personal data was obtained without your consent. The Company will send a copy to  you within 30 days upon obtaining  your request and/or as stipulated by law.

 We may refuse to act on your request where such request could affect the rights and freedom of another person.

 5.2 Right to rectification 

      You have the right to request us to rectify any of your personal data that is incomplete or incorrect.

 5.3 Right to data portability

 You have the right to request us to automatically transfer your personal  data to another data controller, and request to see the personal data transferred to  such other data controller, unless it is technically impossible.

5.4 Right to object

 You have the right to object to the collection, use or disclosure of your personal data at any time unless the collection,  use or disclosure of your personal data  is undertaken under legitimate interest of us or any person or any juristic person, or for public benefit.

5.5 Right of erasure

 You have the right to request us to erase or destroy your personal data or render it unidentifiable in case you believe that your personal data has been  collected, used and / or disclosed against applicable laws or if you deem that it is no  longer necessary for us to keep your personal data under the objectives  of this Notice, or when you exercise your right  to withdraw your consent or your right to object as mentioned above.

5.6 Right to suspend use of personal data

 You have the right to request us to suspend the use of personal data in case we are conducting an investigation per  your request to exercise your right to  rectification, or right to object, or for any other case wherein it is no longer  necessary for us to keep your personal data and we must erase or destroy your  personal data in accordance with  applicable laws but you have requested us to suspend the use of your personal data instead.

5.7 Right to withdraw consent

 You have the right to withdraw your consent at any time, unless it is restricted by law, or by a contract which is beneficial to you.

 However, the withdrawal of your consent shall not affect the processing of personal data which you have previously and lawfully consented to.

5.8 Right to lodge a complaint

 You have the right to file a complaint against us to the relevant data protection supervisory authority if you believe that we have breached or do not comply  with any of our obligations under the applicable personal data protection laws.

6. Security measures of your personal data

We apply proper technical and administrative security measures to protect CCTV data and personal data concerning you from accidental, unlawful, or unauthorized destruction, loss, access, use, alteration, or disclosure.

Contact us

If you have questions or concerns or would like to exercise your rights, please contact us at:

South Asia Law Co., Ltd.

Address: No. 1-7, 5/F Zuellig House, Silom Road, Silom, Bangrak, Bangkok 10500

Tel: 02 636 0585 every Monday to Friday at 09.00-18.00 hours

E-mail: dpo@southasia-law.com

South Asia Law

25 May 2022