These types of customer requests expose our employee personal data to our customers, making our customers “data controllers” of this data. This designation triggers legal obligations for the customer, namely the responsibility to process and safeguard this personal information in compliance with applicable data protection laws and regulations.
Primarily, any such customer requests need to comply with our IBX Policies in this respect. Thereafter, in order to protect our employee data, the Data & Privacy Office (DPO) has created a process that ensures that customers have the necessary data privacy protections and policies in place.
All customers who would like to either install their own CCTV or biometric data readers are required to complete either a CCTV Compliance Assessment Form or Biometric Compliance Assessment Form.
Forms must be completed before equipment is installed or data is collected.
You can reach out to your account team for the latest version of each of these forms.
