Birmingham Airport ‘BlipTrack’ Privacy Notice
Birmingham Airport is collecting your personal data. When we collect personal data, we are obliged legally to provide you with certain information, it is called the “Right to be Informed”. That information is contained in the below Notice. If any of the information we provide to you is not clear enough, there are contact details for Birmingham Airport’s Data Protection Officer further down this Notice, please do not hesitate to make contact and ask for further information.
- Why we need it - the purpose of processing
Birmingham Airport uses the ‘BlipTrack’ system, which detects WiFi and Bluetooth-enabled devices, such as mobile phones, headphones and smartwatches. As a device passes a sensor, the unique device identifier is time-stamped and encrypted. The system then reidentifies the device, as the device passes multiple sensors across the Terminal. The system supplier then provides the Airport with analysis of this data, reporting on direction travelled and time taken by our visitors.
We are collecting and processing personal information via the ‘BlipTrack’ systems for the following purposes:
- Capacity management.
- Improving the layout of existing Airport facilities.
- Improving the passenger experience.
- Why we’re allowed to process your personal information in this way – the legal basis
We are processing your device location data throughout your journey at the Airport. As your device is being carried, the ‘BlipTrack’ system is gathering your physical location data, which under Article 4 (1) of the General Data Protection Regulation (GDPR), is classified as personal data.
To process your personal information, via ‘BlipTrack’, we are relying on the following Article 6 condition of GDPR:
- For the legitimate interests of the Data Controller.
We believe we are doing so with a minimal privacy impact, as no attempt will be made to identify an individual from their unique device identifier.
If you do not understand any of the following and would like clarification, please contact the Data Protection Officer on details at the bottom of this notice.
- Who we will share your personal information with i.e. the recipients?
Your personal data will be shared with the system’s supplier, ‘BlipTrack Systems’, under the ‘Veovo’ brand.
- Where your personal information will be stored or transferred to
Your personal data will be stored on Birmingham Airport servers and ‘BlipTrack’s servers in Denmark.
- How long we will keep your personal information for
The unique identifier used to map your device will be retained for no longer than 24 hours. Once this has been disposed of, your location data will become anonymised and will no longer be classified as personal data.
- Your rights
You are entitled to request the following from Birmingham Airport. These are called your Data Subject Rights and there is more information on Birmingham Airport’s website about each of these and what they mean to you. You can find this information on the Airport’s website birminghamairport.co.uk/dataprotection
Due to the nature of this system, Birmingham Airport will be unable to reidentify you from your location data, therefore it may not be possible to exercise your data subject rights listed within the GDPR 2016.
The unique device identifier used to track your location will be disposed of 24 hours after being capture by Birmingham Airport sensors. After this time, the location data is no longer personal data, as it has been anonymised.
We are processing your data in the legitimate interests of the Airport. The following underlined data subject rights are relevant to the ‘BlipTrack’ system:
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Rights with regards to automated individual decision making, including profiling
Right to object
The right to object is particularly important if we are processing your information under the conditions of a “public task”, or “legitimate interests”, and you can check that information above in section 2. These is because these conditions must be based on not overriding your rights and freedoms against our purposes for using your personal information. If we are using your personal information on these grounds and you wish to object, please contact us on dataprotection@birminghamairport.co.uk
If you have any questions, or wish to contact us and ask us to look at your rights at any time, please contact Birmingham Airports Data Protection Officer, on the below details.
Postal Address:
Kristie Marshman
Birmingham Airport Limited
Diamond House
Airport Way
Birmingham
B26 3QJ
Email: dataprotection@birminghamairport.co.uk
- If you are unhappy with the way in which we use your personal information
If you are unhappy with the way in which Birmingham Airport has used your personal information and you have already been in contact with us (on the above details) and feel we did not resolve your issues to your satisfaction, you can contact the Information Commissioners Office (The UK’s Data Protection Regulator), the details are below. However, the Information Commissioner does prefer that you have contacted Birmingham Airport first with your concerns before you then take those concerns to the Regulator.
Postal Address:
Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Email: casework@ico.co.uk
- Is your personal data being processed because of a regulatory or contractual requirement?
Not applicable to this processing activity.
- Are we using automated decision making or profiling with regards to your personal data?
Not applicable for this processing activity. Your location data’s unique identifier is disposed of by the supplier after 24 hours. Decisions made by Birmingham Airport will be made using the anonymised outputs of this system.
Any further questions about how we use your personal information in regard to the CCTV, that has not been covered in this notice or there is any information above that you do not understand, please contact the Airport on dataprotection@birminghamairport.co.uk.