Camera Privacy Statement

1. Introduction

Brussels Airport Company NV ("Brussels Airport") highly values your privacy and takes the necessary measures to protect your personal data in accordance with (i) the General Data Protection Regulation of 25 May 2018 (or also: the GDPR), (ii) the Belgian law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data,  and (iii) the general Privacy Statement of Brussels Airport available at https://www.brusselsairport.be/en/legal-notices/privacy-policy.

Brussels Airport employs camera surveillance to ensure the safety, security and proper functioning of the airport. This Camera Privacy Statement explains which personal data is processed through cameras, under what circumstances this is done, on what legal basis, and for what purpose.

This Privacy Statement supplements the general Privacy Statement of Brussels Airport. In the event of any discrepancies between the general Privacy Statement of Brussels Airport and the Camera Privacy Statement, the provisions of the latter shall prevail. Capitalized terms not otherwise defined herein have the meaning ascribed to them in the general Brussels Privacy Statement.

Brussels Airport Company NV/SA, Priester Cuypersstraat 3, 1040 Brussels, is the party responsible for the processing of personal data that falls under the scope of this privacy statement, unless otherwise stated. 

2. Processing of personal data when using cameras on the airport grounds

2.1. Purposes for which we use cameras:

At Brussels Airport, cameras are used. As a result, CCTV footage may be recorded of you when you are at the airport. The use of cameras has several purposes, which are explained below:

2.1.1. Camera law

Camera surveillance falls under the provisions of the Law of 21 March 2007 regulating the installation and use of surveillance cameras (Camera Law). This law applies when cameras are used with the intention of preventing or detecting crimes or nuisances, or to maintain public order. This includes surveillance or supervision in the context of:

  • Ensuring security and public order at Brussels Airport.
  • Preventing and detecting criminal offences and nuisances.

2.1.2. Operational purposes

In addition to the surveillance purposes outlined in the Camera Law, cameras are also used for operational purposes. This means that camera images are used to support the proper functioning of the airport. The following of Brussels Airport Company’s services use camera images:

  • Airport Operations Centre (art. 6.1(f) GDPR)

The Airport Operations Centre (APOC) uses camera footage to ensure operational safety and the smooth flow (of processes) at the airport. This footage enables the APOC to monitor situations in a timely manner and respond effectively to incidents, disruptions or emergencies.

  • Stand & Gate (art.6.1(f) GDPR)

Stand & Gate uses camera footage to monitor safety and efficiency at aircraft stands and gates. These images are essential for coordinating activities, preventing disruptions and intervening quickly in the event of irregularities.

  • Fire Emergency Services (art. 6.1(f) GDPR)

Fire Emergency Services uses camera footage to respond quickly and effectively to emergencies and incidents at the airport. The images play an essential role in assessing situations, coordinating actions via ERC (dispatch) and ensuring safety for passengers and staff.

  • Parking management (art. 6.1(f) GDPR)

Parking management uses camera footage to manage the car parks and drop-off zones at the airport.

  • Customer care (art. 6.1(f) GDPR)

Customer Care uses camera footage to investigate (possible) complaints. This is used as evidence to accept or reject a complaint and can help explain why a complaint is not accepted.

  • Health & Safety (art.6.1(f) GDPR)

Health & Safety uses camera footage to investigate and analyse occupational accidents or H&S incidents.

  • Compliance & Certification Unit, Airport Inspection and Airside Inspection (art.6.1(c) GDPR)

The Complinace & Certification Unit and Airport Inspection use camera footage to investigate (potential) breaches of the security processes (Security Incidents) for the security of the airport. Airside Inspection uses camera footage to identify (potential) violations of airport rules and safety on the apron (Safety Incidents).

  • Cargo (art. 6.1(f) GDPR)

Cargo uses camera images to gain insight into operational processes and identify possible bottlenecks, such as mobility problems.

2.2. Personal data disclosed by camera footage

In the context of viewing camera footage, different types of personal data can be revealed:

  • Image recordings of people: Camera images can identify people by visual characteristics such as face, body posture, clothing or accessories.
  • Location data: CCTV footage can show the specific location where a person was at a particular time within the airport (for example, in terminals, baggage halls, secure areas, or car parks).
  • Timestamps: The footage often includes time and date tracking, which can help identify when a person was in a particular location.

Behavioral characteristics: Movement patterns or behaviors can be deduced from the images, for example, walking direction and interactions with others

Vehicle license plates: If cameras capture vehicles (e.g. in car parks or access roads), license plates can also be recorded, which can lead to the identification of vehicle owners.

  • Baggage and personal belongings: CCTV footage can also capture luggage and personal belongings of individuals, such as suitcases, backpacks, etc.
  • …

2.3. Retention of personal data:

In accordance with the Camera Law, all camera images are stored under the management of the Security Department for 30 days. The camera images of the Parking Management Department are retained for 7 days by default.

The retention period of camera images related to incidents is determined based on the incident:

  • Camera images that are part of an Airport Safety or Airport Security investigation are stored for up to 5 years after the investigation has been completed.
  • Camera images relating to a claim that are part of an insurance issue are retained for 10 years after the conclusion of the proceedings.
  • Camera images used in a judicial investigation are kept for 20 years after the incident.

3. Sharing camera images with third parties

Brussels Airport uses the services of third parties, including but not limited to operational service providers, security companies and IT service providers. In this context, Brussels Airport may share your personal data to support operational management, monitoring and complaint handling. These service providers process your personal data only on the given instructions and within the limits of their mandate.

In addition, camera images can be shared with government agencies, such as federal police, ADIV, VSSE and Customs, which have access based on their legal mandate and for their own purposes. In exceptional cases, airport partners, such as airlines and ground handlers, can also receive images and use them for their specific purposes. 

4. International transfers of personal data

Brussels Airport Company (BAC) prefers to process personal data within the territory of the European Economic Area. However, due to the nature of some processes (e.g. if 24/7 support is needed), it may be necessary in certain cases to transfer personal data to processors outside the EEA.

Even if the data centers of these processors are located within the EEA, it may happen that the data is accessed from locations outside the EEA, for example in the event of technical problems or for the provision of 24/7 support. Such access is also considered an international data transfer.

For some processes, processors' data centers may be located outside the EEA or access may be granted from countries such as the United States of America. In such cases, the BAC ensures that an adequate level of protection is maintained. Even when the transfer is carried out through an adequacy mechanism, such as the EU-US Data Privacy Framework for transfers to the United States, BAC remains vigilant in ensuring compliance with privacy regulations by third parties. We set strict requirements for these parties and carry out checks to ensure that they comply with the applicable regulations and adequately protect the data of the individuals concerned.

5. Protection of your personal data

Brussels Airport Company takes various measures to protect the camera footage, including:

  • Download rights are only granted if strictly necessary for specific job profiles and after approval by the Data Protection Officer (DPO).
  • The camera system and its configuration are protected by unique accounts (user IDs and passwords). In addition, all camera activities are monitored via log files.
  • For requests to use camera footage for operational purposes, the DPO conducts a proportionality test to ensure the request aligns with the intended purpose. In addition, access to the images is always limited to employees for whom these images are strictly necessary.
  • Camera footage is stored on specially secured IT servers, equipped with firewalls and backups at secure locations. Images are shared only via a secure application.
  • All employees of Brussels Airport Company are made aware of the processing of camera images. Specific training and guidelines  on the correct use of camera images are provided.

6. Exercising your rights

In accordance with applicable data protection laws, you have rights in relation to (the processing of) your personal data in certain cases:

  • Right to access your personal data: you can access your personal data that we process by sending an email to privacy@brusselsairport.be
  • Right to erasure: in certain circumstances, you have the right to request that BAC erases your personal data. This right applies if:
    • The data is no longer necessary for the purposes for which it was collected.
    • You object to the processing and there are no compelling legitimate grounds for the processing.
    • The data has been unlawfully processed.
    • The erasure of the data is necessary to comply with a legal obligation.
  • Right to restriction of processing: you have the right to restrict the processing of your personal data in the following cases:
    • You dispute the accuracy of the personal data for the period necessary for us to verify the accuracy.
    • The processing is unlawful, and you oppose the erasure of the data and instead request the restriction of its use.
    • You have objected to the processing, and we are waiting for the verification of whether the legitimate grounds of BAC outweigh yours.
  • Right to object to the processing of your personal data: you have the right to object to the processing of your personal data where such processing is based on our legitimate interests. We will no longer process your data unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

If you have any questions about this privacy statement or the processing of your personal data, you can send a signed written request to Brussels Airport, by post: Brussels Airport Company NV/SA, attn. the Data Protection Officer, Priester Cuypersstraat 3, 1040 Brussels, or by e-mail: privacy@brusselsairport.be.

Despite all our efforts to protect your privacy and comply with relevant laws, you may not agree with the way we collect, use and/or process your personal data. In this case, you can also lodge a complaint with the Belgian Data Protection Authority, which you can contact by post: Data Protection Authority/Autorité de protection des données, Drukpersstraat 35, 1000 Brussels or by e-mail: contact@apd-gba.be .

7. Updates

Brussels Airport may amend this Privacy Statement at any time in the future. Such changes will be published here. We therefore recommend that you check this page regularly for updates.

Last updated: 27/12/2024

 

 

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