CCTV Privacy Notice

Lanna Resources Public Company Limited

Date of announcement:

1 Introduction

Lanna Resources Public Company Limited (the “Company”) uses closed-circuit television (CCTV) to monitor its premises and surrounding areas (the “Premises”) and to safeguard the lives, health and property of the Company, its employees, meeting participants, contractors, visitors and other persons entering the Premises (collectively referred to as “you”).

This privacy notice (the “Notice”) explains the collection, use or disclosure (collectively, “processing”) of information that can identify you (“personal data”), together with your rights under the Personal Data Protection Act B.E. 2562 (2019) (the “Act”).

2 Categories of personal data

The Company installs CCTV cameras in visible locations and operates them 24 hours a day, except during system failures or maintenance. CCTV notices are displayed, including in areas that the Company considers require monitoring. The following personal data are collected:

  • Still images.
  • Video footage.
  • Personal characteristics, such as build, height and physical appearance.
  • Images of personal belongings, such as vehicles, bags, hats and clothing.
  • Behaviour, including unusual or suspicious activities.

The Company does not install CCTV cameras in areas where doing so would unreasonably infringe your fundamental rights, such as toilets, shower rooms or private offices.

3 Purposes and legal bases for processing

The Company processes your personal data only to the extent necessary for lawful purposes, relying on the following legal bases:

3.1 Prevention or suppression of danger to life, body or health

To assist you or other persons in emergencies or dangerous situations.

3.2 Legitimate interests of the Company or other persons

  • To monitor and maintain the security of the Company and persons entering the Premises.
  • To protect the property of the Company and persons entering the Premises against damage.
  • To support disciplinary proceedings or compliance with the Company’s internal rules.
  • To support dispute resolution, the exercise of legal claims, and civil or criminal proceedings.

3.3 Compliance with legal obligations

  • To comply with laws relating to investigations or legal proceedings.
  • To comply with orders of legally authorised persons or bodies, such as the police, public prosecutors or courts, in enforcing the law to deter, prevent or investigate unlawful incidents and bring proceedings against offenders.

4 Disclosure of personal data

The Company keeps CCTV data confidential and discloses them where necessary to fulfil the monitoring and security purposes described in this Notice. Recipients may include, without limitation, the following persons or entities:

  • Authorities with statutory powers and duties, to assist or support law enforcement, investigations, inquiries or legal proceedings.
  • Relevant external service providers, such as lessors of buildings or premises, to prevent or suppress danger to your life, body, health or property, or those of other persons.
  • Persons with an interest in an incident or suspicious activity occurring in or around the Premises. Such persons must comply with the Company’s procedures for requesting CCTV data.

5 Retention of personal data

The Company retains your personal data for as long as necessary to fulfil the purposes set out in this Notice or as required by law. The retention period is 30 days. At the end of this period, the Company will consider deleting or destroying your personal data, unless there are other necessary reasons for continued retention.

6 Security of personal data

The Company applies technical and organisational measures to protect personal data. These include restricting access to designated personnel or persons who are authorised or assigned duties and need the data for the notified purposes. Such persons must strictly comply with the Company’s protective measures and maintain the confidentiality of data obtained in the performance of their duties.

When sending, transferring or disclosing personal data to third parties, whether for services in furtherance of its activities, under a contract or under another arrangement, the Company establishes appropriate security and confidentiality measures as required by law to keep personal data secure.

6.1 International transfers of personal data

The Company sends or transfers personal data to destination countries with adequate personal data protection standards. Otherwise, it takes steps to ensure that the transferred data receive adequate protection as required by law. This includes entering into agreements with third parties involved in the transfer, storage or processing of data to ensure compliance with the safeguards and personal data protection measures specified by the Company.

7 Your rights under the Act

You, or a person authorised to act on your behalf, such as a parent or a person exercising parental authority, may submit a request through the contact channels in Section 9. Your rights under the Act include the following:

7.1 Right to be informed

To be informed of the purposes and details of the collection, use and disclosure of personal data through the personal data protection policy or this Notice.

7.2 Right of access and to obtain a copy

To access and obtain a copy of your personal data held by the Company and request disclosure of their source, except where the Company is entitled to refuse the request under the law or a court order, or where the request may adversely affect the rights and freedoms of other persons.

7.3 Right to rectification

To request the correction of inaccurate or incomplete personal data so that they are accurate, up to date, complete and not misleading, subject to applicable legal requirements.

7.4 Right to erasure

To request the deletion, destruction or anonymisation of your personal data so that you can no longer be identified.

7.5 Right to restriction of use

You have the right to request restriction of the use of your personal data in the following circumstances:

  • While the Company is verifying a request to correct personal data so that they are accurate, complete and up to date.
  • Where the Company processes the data subject’s personal data unlawfully.
  • Where the Company no longer needs the data, but the data subject wishes the Company to retain them for the exercise of legal rights, such as bringing or defending legal proceedings.
  • While the Company is verifying an objection to processing.

7.6 Right to object

To object to the processing of personal data where the Company relies on legitimate interests.

7.7 Right to data portability

To request to receive, send or transfer personal data in a format that is generally readable or usable by automated tools or equipment and that permits the data to be used or disclosed by automated means.

7.8 Right to lodge a complaint

To lodge a complaint with the Company for investigation, clarification or resolution of concerns, and with the Personal Data Protection Committee if the Company’s processing does not comply with the Act.

8 Changes to this Notice

The Company may update, amend or revise this Notice from time to time to reflect its internal practices and the Act. The current version will be made available on the Company’s website.

9 Enquiries and exercise of rights

If you have any questions, suggestions or concerns about the collection, use or disclosure of personal data, wish to contact the Data Protection Officer, or wish to exercise your rights under the Act, please contact:

Head Office, Lanna Resources Public Company Limited

888/99 Mahatun Plaza Building, 9th Floor, Phloen Chit Road, Lumphini, Pathum Wan, Bangkok 10330, Thailand

Telephone: +66 2 253 8080, +66 2 253 6820

Fax: +66 2 253 5014, +66 2 253 6822

PDPA@lannar.com