Facial Recognition Policy

11th June 2019

NOTE: This policy is out of date and is displayed for record only. The latest version is available here.

1. INTRODUCTION

1.1 We make every effort to ensure the building is a safe and enjoyable environment for our visitors – and equally, those who have advised us they wish to self-exclude, we do our best to respect and uphold these wishes.
1.2 To facilitate these efforts, we have employed the use of facial recognition software in the building.
1.3 Facial recognition software is used for the purpose of detecting individuals who are subject to exclusion from The Hippodrome Casino and other licenced premises for disorderly conduct or similar activity and we are obliged to prevent entry as part of our licencing conditions.
1.4 We also have an obligation to detect individuals who have enrolled on the SENSE (Self-Enrolment National Self-Exclusion) scheme, so have asked us not to allow them on the premises.

2. IS MY IMAGE SUBJECT TO THIS PROCESSING?

2.1 If your image is held on our exclusion database, then your image will be processed by the system and it will alert us to your attempted entry. You will then be approached by a member of our security team.
2.2 If you image is NOT held on our exclusion database, then your image will be immediately deleted by the system.

3. LAWFUL BASIS OF PROCESSING

3.1 Where we have a need to exclude due to disorderly conduct, or due to our gambling obligations, this is to comply both with a legal obligation to which the data controller is subject to – GDPR Article 6 (1)(c) and when the processing is carried out in the public interest – GDPR Article 6(1)(e).
3.2 Where an individual has enrolled on the SENSE scheme, it is necessary for the performance of the contract you enter with us – GDPR Article 6(1)(b). We also believe it to be in the legitimate interest of the excluded – GDPR Article 6(1)(f).
3.3 Images will also be sent to and received from other UK land-based casinos via the National Casino Forum network (NCF) to ensure exclusions are upheld where appropriate. Our lawful basis for the sharing of this data again comes under “compliance with legal obligation” – GDPR Article 6 (1)(c) or “legitimate interest” where the exclusion is voluntary – GDPR Article 6(1)(f).
3.4 The Hippodrome Casino have concluded it is neither feasible, nor practical to gain explicit consent which is usually required for the processing of biometric (special category) data.
3.5 Instead, we rely on GDPR Article 9(2)(g) that permits the processing of biometric data for security purposes when carried out for reasons of substantial public interest in the area of public health (gambling addition).

4. DATA INFORMATION

4.1 Data Roles:
a. Facial Recognition Software – The Data Controller is Hippodrome Casino Ltd, Cranbourn Street, Leicester Square, WC2H 7JH, whom have control of; the collection source, use purposes, legal basis, retention, locations of storage and the security of personal data within this system and other systems or parties in delivery of the service.
b. Facial Recognition Software – The Data Processor is NEC (UK) Ltd, Athene, Odyssey Business Park, West End Road, South Ruislip, Middlesex. HA4 6QE and acts on the instruction of Hippodrome Casino Ltd.

5. DATA INFORMATION

5.1 Data Sharing:
a. Where personal data is shared with, or received from other establishments, Hippodrome Casino Ltd will be a joint controller of this.
b. A full list of establishments we share data with can be found on our Privacy Policy. Where data is shared, you are subject to the Privacy Notices of each respective establishment.
5.2 Data Collection / Retention:
a. If your image is to be used within the system, it will be taken from your records on our system, or those supplied to us by other establishments. It will be retained on our excluder database for a period of up to 5 years.

6. PRIVACY CONCERNS

6.1 Should you wish to exercise your privacy rights or have concerns over any elements of these processing activities, please contact the Hippodrome Privacy Office and we will be happy to help – [email protected]