CCTV Privacy Notice

Each hotel property within THE BAYLEAF HOTELS brand has installed closed-circuit television (CCTV) cameras within its premises and on its perimeter area to monitor any unwanted or unsafe activity. In accordance with the Data Privacy Act of 2012, The Hotel must ensure that these CCTV cameras do not have unnecessary impact on the privacy of our guests, personnel, and other data subjects.

We have created a privacy policy to govern the collection, use and disclosure of images captured by CCTV cameras. This CCTV privacy notice is designed to inform you of our reasons for installing a CCTV system, and where personal information has been collected, your rights in relation to that information.

There is nothing in this notice that limits or excludes your rights under the Data Privacy Act of 2012, its Implementing Rules and Regulations, memorandum circulars, and advisories issued by the National Privacy Commission.

What information is being collected?

We have placed CCTV cameras within our building and perimeter area for security and safety purposes. These cameras may record footage of our guests, personnel, visitors, passersby and others. It may record footage of yourself as you pass through the areas where our cameras are located. We consider this footage to be your personal information and will do our best to ensure that it is properly managed according to the law, NPC’s guideline concerning the operation of CCTV, and our policies pertaining to data privacy.

Purpose

The Bayleaf Hotels aim to provide a safe and secure environment to protect our guests, our personnel, our property, and the interest of our stakeholders.

Closed Circuit Television {CCTV) Cameras are installed and operated for one or more of, but not limited to, the following purposes:

  1. Assist to facilitate service to our guests, employees and visitors
  2. For public safety
  3. To improve security and deter criminal activity within or outside our hotels’ premises
  4. Protect our furniture, fixtures, equipment, accessories and other assets
  5. Monitor transactions for playback if an error has occurred
  6. Monitor our areas for any sign of malicious intent
  7. Aid in establishing bases for corrective measures
  8. Monitor unauthorized access and trespass in controlled areas
  9. Monitor compliance with house rules, company policies and workplace procedures
  10. Capture information that could be used to investigate a crime, a matter concerning health, safety, and security, a misconduct, or an incident concerning guests and personnel
  11. To assist in effectively managing the company and its resources
  12. To aid the hotels, particularly in training, evaluating, and correcting our employees in relation to customer service and conflict management
  13. For ancillary purposes such as resource allocation and management

Scope

  • This policy applies to all employees, contractors, guests, visitors, and the public who may be on or near the hotels’ premises
  • This policy applies to non-covert operating of our CCTV system within or around the hotel’s premises

Notice

  1. The system may include, but is not limited to, a range of CCTV cameras.
  2. Cameras are deployed and located in various locations of the building, and in our perimeter areas. Based on need, it may be relocated from time to time, and/or augmented with additional devices for visibility and other sensory requirements. Our CCTV may cover the following, but are not limited to these areas:
    • Entrances
    • Lobby
    • Reception
    • Restaurants
    • Public area including hallways
    • Cashier
    • Certain Offices
    • Perimeter area
  3. Hotel cameras will normally record videos only. The hotel reserves the right to deploy camera devices with audio capability and record both video and audio, accordingly.
  4. When footages are available and requested before the CCTV system’s auto-deletion of such, the relevant footage will be provided to the requesting data subject or authorized entity upon request.
  5. Requests must use the hotel’s official form for this purpose, and must be satisfactory validated by our authorized security personnel, with corresponding documents attached for identity and veracity, and with proper authorization and approval from the hotel’s security officer as well as the hotel’s highest-ranking manager, or designated authorized representative in his/her absence.
  6. Signages advising the presence of CCTV equipment in the hotel will be installed at entry points to the hotel’s premises.
  7. Internal incidents involving personnel for misconduct detected by CCTV will be handled in accordance with the hotel’s house rules, company policies, workplace procedures, code of conduct, or the employee’s individual employment agreements.
  8. Any criminal activity recorded on CCTV will be handled in accordance with the hotel house rules, company policies. workplace procedures, code of conduct, or the employee’s individual employment agreements, and in accordance with the requirements of a criminal investigation.
  9. The placement of CCTV cameras is meant primarily for security and safety, among other legitimate purposes, and is designed not to unreasonably intrude on the privacy of individuals.
  10. All cameras normally operate 24/7, 7 days a week, to ensure utmost security of individuals and company assets.
  11. List of Roles and User access
    • Full System Access to all CCTV camera features and configuration: ICT Personnel
    • Live View, Playback and Export: Authorized CCTV Operator, Security Officer
  12. For exporting of CCTV footage, a written authorization from the hotel’s Security Officer and the highest-ranking manager in the hotel must be secured before conducting any footage export by the CCTV Operator on duty. This requires a direct supervision by the Security Officer to ensure that only relevant footages are exported from the system.
  13. Storage of CCTV Footage
    • CCTV footage will be recorded and stored in the hotel’s storage system with RAID volumes consisting of various hard drives for a maximum of 30 days before being overwritten in a continuous recording cycle.
    • Access to the CCTV’s Network Video Recorders, storage system, and Central Management System is restricted to authorized persons listed under “Notices” Item 11.
    • The hotel, at its discretion, can opt to store recordings of critical cameras in secured cloud storage systems.
    • Where an incident or suspected incident has been identified, and with corresponding approval by the hotel’s highest-ranking manager, the footage may be retained for a longer period as needed to aid in investigation or other lawful purposes.
  14. CCTV Information Access
    • Recorded footages are confidential to the hotel. Based on the guidelines set by the National Privacy Commission, data subjects have the right to CCTV footages where they may have appeared. All requests to view footages relating to individuals will be handled in accordance with company policies and guidelines set forth by the NPC.
    • In compliance to company policies and guidelines set forth by the National Privacy Commission, subject to review and verification of the request or subpoena, a copy of relevant CCTV footages may be given to a public authority such as the police where any criminal activity is suspected, or a request was made in accordance with police procedure.
    • A request by the public to view footages that contain information relating to other individuals must be in writing and will be dealt with as either as a matter to be referred to the public authorities such as the police, or made accessible to them by official request or by other lawful means; or where the footage requested for viewing only shows the individual who has made the request, the request will be dealt with in accordance with the Data Privacy Act of 2012 and corresponding circulars from NPC related to CCTV.
    • Any request to view footages may be limited by the need to protect other persons’ privacy. A request to view the footage may not immediately be granted if it appears to reasonably breach the privacy of others. In such circumstances, a written description may be provided by the hotel to describe what is seen on the footage, in a manner consistent with the provision of the Data Privacy Act of 2012, its IRR and and corresponding circulars from NPC related to CCTV.
    • When necessary, requests that are questionable, or have elements of doubt and/or suspicion, will be escalated to the company’s Office of Data Privacy. In cases such as these, analyses and recommendation for approval will be requested from the DPO.
  15. Complaints or questions concerning CCTV are to be forwarded in writing to the Office of Data Privacy, Lyceum of the Philippines University.

Changes

THE BAYLEAF HOTELS reserves the right to update or change this CCTV Privacy Notice and its Privacy Policy at any time as the need arises.

Contact

For any query or concern about this CCTV Privacy Notice, please contact:

Office of Data Privacy
Lyceum of the Philippines University

The Bayleaf Intramuros
Muralla corner Victoria streets, Intramuros
1002 Manila
Email: privacy.intramuros@thebayleaf.com.ph

The Bayleaf Cavite
Governor’s Drive, Manggahan
4107 General Trias, Cavite
Email: privacy.cavite@thebayleaf.com.ph

 

Note: This document is in the process of being reviewed. We will update this once finalized.
Last edited: October 10, 2024