(CCTV) Closed-Circuit Television USE PRIVACY NOTICE

Introduction  

Okavango Diamond Company (ODC) is a rough diamond marketing company that is wholly owned by the Botswana Government. ODC is the Data Controller responsible for the processing of personal data captured through the CCTV system. Responsible use of your personal data is our priority. We ensure that we process your personal data in accordance with applicable Data Protection Laws, and we do this by ensuring that there is transparency in how we process your data, and by further ensuring that you have autonomy and control over how we use your personal data.  

 

For the safety and security of our employees, vendors, customers, visitors, company property and assets, all our premises are being monitored by 24-hour video surveillance. The Legal Justification of processing your personal data is that of Legitimate Interest in maintaining a safe and secure environment due to the nature of our goods.  

 

This notice explains how CCTV footage is collected, used, and protected. 

 

Contact Details: 
Email: dpo@odc.co.bw  
Telephone: +267 3602421  
Address: Plot 67782, Block 8 Industrial, Gaborone, Botswana 

 

Purpose of CCTV Monitoring 
CCTV cameras are installed for the following purposes: 

  • Ensuring the safety and security of employees, vendors, customers, visitors  

  • Protecting company property and assets 

  • Preventing and detecting crime or misconduct 

  • Supporting investigations of incidents or complaints 

  • Assisting law enforcement authorities where required 

CCTV systems are not used to monitor employee performance unless necessary as part of an investigation. 

 

Location of Cameras 
CCTV cameras are installed in strategic locations across ODC premises for the protection of goods, including but not limited to the below:  

  • Building entrances and exits 

  • Reception areas 

  • Parking areas 

  • Building corridors  

  • Diamond floor areas  

  • Search rooms  

  • Perimeters  

 

Cameras are not installed in private areas such as restrooms, changing rooms, or other areas where individuals have a reasonable expectation of privacy.  

 

Lawful Basis for Processing 
The collection and processing of CCTV footage is carried out in accordance with the applicable Data Protection Laws and is based on the organisation’s legitimate interest in maintaining security and safety. 

 

Access to CCTV Footage 
Access to CCTV recordings is restricted to authorised personnel only, including: 

  • Security personnel 

  • The Data Protection Officer (where applicable) 

 

Footage may be shared with law enforcement agencies, regulatory authorities where required by law and any other request may be granted where it is reasonable to do and if it is in compliance of the Data Protection Act.   

 

Retention of Footage 
CCTV footage is retained for a period of 120 days unless required for investigation, legal proceedings, or regulatory purposes. After this period, the footage is securely deleted.  

 

Data Subject Rights 
Individuals whose images are captured by CCTV have rights under data protection law, including,  

  • The right to request access to their personal data 

  • The right to request deletion where applicable. Deletion will only be allowed following internal processes and reviews, and when there is no lawful basis to  

  • The right to lodge a complaint with the Company Data Protection Officer on the above-mentioned contact details. Or escalate it with the Botswana Information and Data Protection Commissioner.  

 

Security of Footage 
ODC has implemented appropriate technical and organisational measures to protect CCTV recordings against unauthorised access, loss, misuse, or alteration i.e. In line with the company Data Protection, Security Policies, ICT Processes guided by the Policies, Procedures and related.  

 

Changes to this Notice 
This notice may be updated from time to time to reflect operational or legal changes.