Shangri-La Hotel Public Company Limited ("Hotel", "we", "us", or "our") is using closed-circuit television (CCTV) devices for monitoring our designated space within and around our buildings and facilities to protect life, health, and property. We collect personal data of all customers, visitors, tenants, employees, directors, contractors, workers or any individuals entering the monitored space within our buildings and facilities (collectively referred to as "you" or "your") through the use of CCTV devices.
Most data protection laws around the world, including Thailand, consider the use of CCTV devices and similar surveillance technologies to be personal data collection. Therefore, the collection, use, disclosure, and overseas transfer of CCTV footage and images must be conducted in accordance with applicable data protection laws. We will ensure the use and operation of CCTV devices by our Hotel stands up to scrutiny and complies with applicable data protection laws and regulations.
1. What Personal Data we collected
The Hotel collects your moving or still images and belongings, e.g., vehicles, when entering the monitored space in our buildings and facilities through the CCTV devices ("CCTV Data").
2. Why we collect, use and/or disclose your Personal Data
2.1 The Hotel may collect, use, disclose, transfer, and/or carry out any operation, including but not limited to recording, holding, adapting, altering, modifying, destroying, deleting, retrieving, combining, copying, transmitting, storing, extracting, amending, or adding, related to your CCTV Data and other Personal Data concerning you, for the "CCTV Monitoring Purposes" as listed below:
2.2 We will install CCTV devices in plain sight. The areas we will not install CCTV devices are in guest rooms, staff rooms, changing rooms, toilets, shower rooms, or any other areas designated as staff rest areas.
2.3 Our CCTV devices are in operation 24 hours a day and 365 days a year.
2.4 We will place signage at the entrance and exit points, and the monitored areas to alert you that a CCTV installation is in use.
3. Legal bases
The Hotel will not collect, use, disclose, process, transfer, and/or carry out any operation, including but not limited to recording, holding, adapting, altering, modifying, destroying, deleting, retrieving, combining, copying, transmitting, storing, extracting, amending, or adding, related to your CCTV Data and other Personal Data concerning you, without consent except upon the following bases:
4. To whom we may disclose or transfer your Personal Data
4.1 The Hotel will keep CCTV Data concerning you confidential and will not disclose or transfer it except to our subsidiaries and affiliates, who may be located overseas, to achieve the CCTV Monitoring Purposes provided in this policy.
4.2 Third parties to which we may disclose CCTV Data and other Personal Data concerning you include:
5. International transfers of your Personal Data
5.1 The Hotel may disclose or transfer your CCTV Data as part of necessary steps to ensure protection of your health, personal safety, and belongings, to our subsidiaries and affiliates that are outside of Thailand. Such disclosure or transfer may only be done by obtaining your consent, unless there are any other compelling legitimate grounds (e.g. to perform the contract terms between us and other persons for your benefit) as permitted by applicable laws.
5.2 If your CCTV Data is transferred to destination countries where the standard of protection available is not sufficient under the applicable laws on data protection in Thailand, we will take necessary steps to protect the Personal Data transferred to other persons internationally to reach the same level of protection as we provide with respect to your CCTV Data, and in compliance with the applicable laws on data protection that are in effect at that time.
6. Security measures
6.1 The Hotel uses reasonable organizational, 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.
6.2 The Hotel will from time to time review and update our security measures as necessary or upon development of the concerning technology to ensure effective and appropriate security measures, and in line with minimum legal requirements as prescribed by the relevant governmental organizations.
7. How long do we keep your Personal Data
The Hotel will retain your CCTV Data in our system for a minimum of 1 month and up to a maximum of 3 months, or for the period necessary to fulfil our duties to achieve the CCTV Monitoring Purposes prescribed in this policy. When we are no longer permitted by the applicable laws to store your CCTV Data, we will remove it from our systems and records. In the event that judicial or disciplinary action is initiated, your CCTV Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by the applicable laws.
8. Your rights as a data subject
If you believe that you have been recorded by our CCTV devices, subject to applicable laws and exceptions thereof, you may have the following rights with respect to your Personal Data:
9. Our Contact Details
If you have concerns or questions regarding this policy or if you would like to exercise your rights in relation to your CCTV Data, please contact us at:
SHANGRI-LA HOTEL PUBLIC COMPANY LIMITED
Address: 89 Soi. Wat Suan Plu, New Road, Bang Rak, Bangkok 10500
Telephone: 66 (0) 2236 7777; or
Our data protection officer by email at firstname.lastname@example.org