PRIVACY STATEMENT ON CCTV SYSTEM

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Policy, we explain how we use personal data collected via Closed Circuit Television (CCTV) camera systems in LRT Line-1.

1.         CAMERA SYSTEMS WE OPERATE

Our CCTV system is used to capture and monitor images of events that take place in specific locations in real time. The images may also be recorded on a computer hard drive or magnetic tape depending on the type of camera. Cameras may be focused on a fixed location, set to scan a particular area, or operated remotely by specially trained operators.

2.         WHY WE OPERATE CAMERAS?

Under the Republic Act No. 10173 or the Data Privacy Act of 2012 (“DPA”), we are only allowed to use personal information if we have a “legitimate purpose” to do so. In the case of CCTV cameras, our concession agreement with the government requires us to have a CCTV camera system installed within the premises of LRT Line-1. We operate CCTV cameras to perform tasks in support of our operating franchise and this concession agreement – namely, the delivery of safe and efficient transport services through LRT Line-1.

We operate CCTV cameras for the following purposes:

• To maintain the safety and security of our passengers, colleagues and stakeholders, members of the public, national security, detection and prevention of crime and transportation security;
• To monitor passenger flow and demand throughout LRT Line-1 to maximize resources and optimize the passenger experience;
• To support the effective management of LRT Line-1 operations and any incidents;
• For investigative purposes or as evidence to support any investigation of incidents or formal follow-ups to such incidents;
• To provide the Department of Transportation (“DOTr”) and Light Rail Transit Authority (“LRTA”) with evidence of our compliance with operating franchise and concession obligations; and
• To enforce train operating and passenger management rules.

3.         WHERE ARE THE CCTV CAMERAS LOCATED?

We have CCTV cameras in and around LRT Line-1 passenger stations, depots, office buildings and areas (including station teller booths and treasury and safety deposit rooms), and power substations. We may eventually have CCTV cameras in trains.

4.         HOW IS YOUR PERSONAL DATA PROTECTED?

We endeavor to maintain physical, technical, and procedural safeguards to control access to, and use of, personal data associated with our CCTV systems. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

CCTV footages are retained in a secure environment and are only accessible to authorized personnel who have a legitimate reason to do so.

5.         WHEN DO WE DISCLOSE YOUR PERSONAL DATA?

CCTV footage and imagery may be handled and used by the following recipients to maintain safe, secure, and efficient LRT Line-1 operations:

• LRMC personnel;
• police and other law enforcement agencies;
• DOTr and LRTA representatives;
• our retained security agency; and
• other LRT-1 service providers.

On a case by case basis we may use and share CCTV images for research and analysis purposes. For example, these may be used to improve the management of health and safety incidents, or travel demand management.

In some circumstances, other disclosures of personal data (including CCTV images) to the police and other law enforcement agencies are permitted by law, if they relate to the prevention or detection of crime and/or the apprehension or prosecution of offenders. Before any such disclosure takes place, the police are required to demonstrate that the personal data concerned will assist them in this respect. Each police request addressed to us is dealt with on a strictly case-by-case basis to ensure that any such disclosure is lawful.

6.         HOW LONG IS YOUR PERSONAL DATA RETAINED?A

CCTV footages are kept for 90 days, after which it is erased. Footage required as evidence or in investigations may be retained for more than 90 calendar days and will be securely disposed upon completion and conclusion of the purpose for which it has been retained.

7.         WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?

You may request copies of images or footage of yourself by making a request for such access. Please note that in most cases, CCTV footage is kept for a limited time, and any request should be made immediately.

In making your request, you will need to provide as much information as possible about when and where the images were captured (i.e., the specific date, time, and location). Along with your request, you will also need to submit a clear full length photograph of yourself so that we can identify you when searching for the relevant images.

When requesting access to CCTV footage, we may charge you a fee which you will be advised in advance. If you require assistance in preparing your request, you may contact the office of our Privacy Officer.

Your rights with respect to your personal information are not absolute. There are instances when laws or regulations allow or require us to withhold from you some or all of your personal information or CCTV footage requested. In addition, CCTV footage may have been erased in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

8.         INQUIRIES OR CONCERNS?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

9.        PRIVACY OFFICER

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address:	Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number:	(02) 5318-5762 loc. 5726
Email address:	dataprivacy@lrmc.com.ph

10.        REVISIONS TO THIS PRIVACY POLICY

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

11.         INTERPRETATION OF THIS PRIVACY POLICY

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.