Birmingham Airport Thermal Imaging Privacy Notice
Birmingham Airport Limited – Privacy Notice
COVID-19 Thermal Image Screening
Birmingham Airport is collecting your personal data. When we collect personal data, we are legally obliged 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.
1. Why we need it - the purpose of processing
In response to the COVID-19 pandemic, Birmingham Airport will record your skin temperature through a thermal imaging device ‘bolted on’ to our existing CCTV cameras. Thermal imaging cameras will be located at the entrance to the terminal building.
A portable handheld device may also be used where an initial scan has shown a temperature of above 38 degrees and the individual wishes to be re-tested following a short rest period.
Health data will be captured to identify any individual with a skin temperature above 38 degrees, as a high temperature is a symptom of COVID-19. This reading will be taken from a distance at the forehead. Access to the terminal building will be denied to those with a skin temperature of 38.1 degrees, and above, as a precaution to safeguard all visitors and staff from exposure to COVID-19.
Birmingham Airport will be guided by Public Health England and World Health Organisation advice. Thermal imaging technology will only be used in the context of a pandemic and will be disabled when the level of risk to visitors and staff has lowered to an acceptable level.
2. Why we’re allowed to process your personal information in this way – the legal basis
To process your personal information via CCTV we are relying on the following schedule 2 conditions of the GDPR. 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.
• Article 6 condition – Legitimate interests
• Article 9 condition - Public Health;
• and the associated schedule condition in DPA2018 Schedule 1, part 1, paragraph 3*.
*The processing is necessary for reasons of public interest in the area of public health, and
(b)is carried out— (ii)by another person who in the circumstances owes a duty of confidentiality under an enactment or rule of law.
3. Who we will share your personal information with?
Thermal images will be processed by our partner Mitie, through a live feed, at a security podium. This is to enable Mitie to identify those with a temperature above 38 degrees and approach that individual to prevent entry into the Terminal. Your stored thermal images and associated temperature reading will not be shared with any third-party and will not be used for any other purpose.
4. Where your personal information will be stored or transferred to
Your personal information will be stored on secure Airport servers based within the UK.
5. How long we will keep your personal information for
Thermal images taken during this time of Pandemic will be retained by the Airport for 14 days, at which point the system will automatically overwrite.
6. 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 by going to birminghamairport.co.uk/dataprotection
• 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 exercise any of your above Rights, please contact Birmingham Airport’s Data Protection Officer on the below details.
Postal Address:
Birmingham Airport Limited
Diamond House
Airport Way
Birmingham
B26 3QJ
Email: dataprotection@birminghamairport.co.uk
7. 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
8. Is your personal data being processed because of a regulatory or contractual requirement?
No.
9. Are we using automated decision making or profiling with regards to your personal data?
No.
Any further questions about how we use your personal information that has not been covered in this notice or there is any information above that you do not understand, please contact the Data Protection Officer on dataprotection@birminghamairport.co.uk.