LIVE FACIAL RECOGNITION “LFR” – Privacy Notice
Welcome to The Hippodrome Casino
We make every effort to ensure our premises are enjoyable and also safe for all our customers and to assist our efforts, we use Live Facial Recognition (“LFR”) at our entrances.
Why Is LFR Used?
We use LFR to protect persons who have elected to register with the Self Enrolment National Self Exclusion Scheme (the “Scheme” or “SENSE”).
The Scheme is operated by Self Enrolment National Self Exclusion Ltd [SENSE] on behalf of all land-based
casino premises licensed in Great Britain by the Gambling Commission. Under the Scheme there is a voluntary agreement between the customer who has registered with the Scheme and all participating land-based casinos.
The agreement between the parties is governed by the terms and conditions of the Scheme.
As part of our licensing conditions, The Hippodrome Casino is required to take all reasonable measures to uphold the self-exclusion wishes of individuals who have asked us not to permit them entry to land-based casinos. Due to our open door policy and visitor numbers, the use of LFR is considered a proportionate measure to assist us in the detection of SENSE participants who attempt to enter the casino, thus breaching their self-exclusion agreement.
LFR uses biometric data, which is classed as special category personal data. The system creates a digital template of an image that exists on the SENSE database and creates an alert for our staff when a match is identified i.e. a SENSE participant passes a camera in attempting to enter our premises.
Is my Image subject to this processing?
• All entrances to The Hippodrome Casino are covered by LFR cameras – one per entrance. All those entering or attempting to enter our premises are captured by the cameras. The cameras are carefully positioned to cover internal areas only. No external areas are captured.
• If your image is held on the SENSE database, then your image will be processed by the system and our staff will be alerted to your attempted entry. Our staff will manually monitor your activity on our CCTV to ensure a correct identification. In the event that you are identified as a match to an existing SENSE participant, then you will be approached by a member of staff for further verification and will be escorted from the premises.
• If your image is NOT on the SENSE database, then following capture and processing by LFR (which takes a second) it will be deleted immediately. No images are retained by us beyond this initial processing. Individuals captured by LFR , but not on the SENSE databases are ‘pixelated’ so you cannot be identified by our staff at any point. Please see our “Frequently Asked Questions” document which will answer any questions you may have. However, you are also welcome to contact us at: [email protected].
Nature of Processing
• When an individual enrols on the Scheme, they are notified of the terms of the agreement. The SENSE Privacy Notice references the use of LFR by certain operators, which includes The Hippodrome Casino.
Lawfulness of Processing
• Legitimate Interest: The Hippodrome Casino has identified legitimate interest (UK GDPR Article 6.1.f) and the UK GDPR Article 9.2.g – Substantial Public Interest for the safeguarding of children and individuals at risk as the appropriate lawful basis for the processing of special categories of data. Our balancing test demonstrates that it is reasonable for all visitors to the casino to be checked by LFR upon entry or attempted entry in order to protect any vulnerable persons.
We are aware that Self Enrolment National Self Exclusion Ltd, as detailed in their own privacy notice, has
identified contractual obligation and legal obligation as their legal bases of processing.
• Contractual obligation: you enter into a contract with Self Enrolment National Self Exclusion Ltd as part of your self-exclusion agreement.
• Legal obligation: British casinos are obliged under the Gambling Act 2005 to protect vulnerable people,
notably those with gambling issues.
Data Information
Data Roles: – Facial Recognition Software
Hippodrome Casino Limited • Self Enrolment National Self Exclusion Ltd • NEC (UK) Limited
To operate the Scheme, Self Enrolment National Self Exclusion Ltd is the Data Controller. Self Enrolment
National Self Exclusion Ltd is a company registered in England & Wales under company number 13998497.
Address: EMW, Seebeck House, Davy Avenue, Knowlhill, Milton Keynes, MK5 8FR.
Hippodrome Casino Limited is also a Data Controller, meaning a Joint Controller relationship is in place.
Hippodrome Casino Limited, of Cranbourn Street, Leicester Square, WC2H 7JH, as an operator licenced by
the Gambling Commission is obliged to meet the requirements set out in the Licence Conditions and Codes of Practice and in doing so, we participate in the Scheme.
The Sub-Processor is NEC Software Solutions UK Limited, Queens Court, Wilmslow Road, Alderley Edge,
Cheshire, SK9 7RR and acts on the instruction of Hippodrome Casino Limited for the purpose of operating the LFR system.
Data Sharing:
The only instances where personal data is shared with, or received from other parties, is as part of the Scheme, of which Hippodrome Casino Limited is a Joint Controller. No other data from the LFR system is shared with other parties and LFR is only used for the purposes of detecting those persons participating in the Scheme.
Data Collection:
SENSE data is collected from you at the time of enrolment on the Scheme.
Your image will be taken from the existing customer record on our system, or that supplied to us as part of the Scheme.
If you decline the upload of your image to the system, then it will impede our ability to detect your attempted entry and may result in you breaching your exclusion and the terms of the Scheme to which you have agreed.
Data Retention:
As part of the Scheme, your image will be retained on the SENSE database for a minimum of six months, or extended period requested by you until such time as you are removed from the Scheme in accordance with the agreement between you and the Scheme.
Technical & Security Measures:
LFR is hosted on a dedicated server in the UK. Updates to SENSE are received via a secure API feed.
Individual Rights
Your individual rights are the same as those detailed in the Hippodrome’s existing Privacy Notice. If you wish to exercise your privacy rights or have any concerns regarding these processing activities, please contact the Hippodrome Privacy Office: [email protected].
If you are based in the EU / EEA, you can still contact us directly. Alternatively please contact us via our GDPR EU/EEA Representative, DataRep:
• [email protected] – In order to ensure a timely response to your enquiry please ensure you quote “Hippodrome Casino” in the subject line of your e-mail.
• Online webform at www.datarep.com/datarequest
• At the postal address of your country of origin – the full list of which can be accessed here.
• Alternatively, please contact Self Enrolment National Self Exclusion Ltd directly: [email protected].
Right to complain – you have the right to complain at any time to the Information Commissioner’s Office (ICO) regarding data protection issues that relate to the data processing activities of the Hippodrome Casino Limited – https://ico.org.uk
Last Updated: August 2024
We reserve the right to amend this Privacy Notice at any time
LIVE FACIAL RECOGNITION “LFR” – FAQs
What is LFR?
LFR captures and analyses facial images in real-time from live video feeds, comparing them against a database of selected images – in this case those individuals that have registered with (“SENSE” or the “Scheme”) the Self Enrolment National Self Exclusion Scheme.
How does our LFR work?
Our LFR continuously scans live video feeds, detecting faces and comparing them in real-time against a database. When a match is found, it alerts our staff who then use CCTV to verify the correct identity, before any relevant action is taken.
Where and when is LFR being used?
All entrances to the Hippodrome Casino premises are covered by LFR, 24 hours a day, 7 days a week. Clear signage is displayed before you enter the building, and a privacy notice dedicated to LFR can be found at
https://www.hippodromecasino.com. LFR will only detect you once on our premises.
Am I on the database?
The database used with our LFR only contains the details of those individuals who have registered with SENSE – https://sensescheme.com
Is everyone scanned by the LFR system?
Yes. However, it only alerts our staff if a facial image matches an image on the database. If you are not enrolled as a member of SENSE you are not on the database and the system deletes your image within one second of capture.
How accurate is the LFR system?
Our LFR operates to a very high accuracy rate – and this has been verified by our staff during a thorough testing process prior to implementation. However, all matches / alerts are subject to secondary verification by our staff to eliminate false positive matches.
Are you recording all the video feeds?
No, we don’t record the LFR video feeds. LFR processes images in real-time without storing them. If you are not on the database, your image is deleted automatically within one second of capture.
Can I ‘opt out’ of LFR?
No – Due to the nature of how LFR is intended to operate and the importance of ensuring persons registered on SENSE are not able to enter the casino premises, individual opt-outs are not possible. In conjunction with the Scheme, we believe it is proportionate for all visitors to be scanned momentarily to prevent problem gamblers from breaching their exclusion agreements. If you do not wish to be scanned, we simply advise not to enter the premises.
Is the system GDPR compliant?
Yes – Our use of LFR complies with GDPR as supported by a thorough Data Protection Impact Assessment (DPIA) carried out prior to implementation. This is supplemented by a robust and well-designed privacy framework governing the use of the system including testing, staff training, stakeholder consultation. This serves to minimise intrusion and protect your important rights as individuals.
Can I make a data subject access request off the back of the system processing my personal data?
Yes – However, due to the system deleting the image within one second of capture, if you are not on the database, your data subject access request will not return any personal data.
I’d like to know more about your LFR – where can I find this and who do I contact?
In the first instance, please contact the Hippodrome Casino Data Protection Officer –
[email protected]. Alternatively, contact Self Enrolment National Self Exclusion Ltd the operator of the scheme and Joint Controller – [email protected]