Draft — under legal review. Not yet binding.
Shinrai
Draft v0.1 — under legal review. Not yet binding.

CCTV and AI monitoring notice: template for customers

This page is a template for businesses that use Shinrai Vision at their sites. The business that operates the cameras is the Data Fiduciary under the Digital Personal Data Protection Act, 2023 (the "DPDP Act") and is responsible for giving notice to the people its cameras capture. [[LEGAL_ENTITY_NAME]] ("Shinrai") provides the Service as that business's Data Processor.

Replace the highlighted placeholders with your own details, adapt the text to the cameras and features you actually use, and have it checked by your own adviser. This template is provided for convenience and is not legal advice.

How to use this template

  • Put the short sign (Part A) at every entrance to a monitored area, where people can read it before they enter, and at any vehicle gate whose camera reads number plates.
  • Make the full notice (Part B) easy to obtain, for example at reception, on your website or on request.
  • Offer both in English and in the local language or languages used by people at your site. The DPDP Act gives people the option to read a notice in English or in any language listed in the Eighth Schedule to the Constitution.
  • Remove the lines about number plates if none of your cameras uses number-plate mode, and the lines about hazards if you do not monitor for them.
  • Do not place cameras in toilets, changing rooms or other places where people expect privacy.
  • If children use your site, take advice on the DPDP Act's rules on children's data before relying on this template.
  • Tell your employees separately how cameras are used at work.
  • Decide how long you keep alerts, delete older alerts in the portal, and state that period in the notice.
  • Keep a record of where and when you put up the signs.

Part A: sign text

CCTV in operation: AI-assisted monitoring

This area is monitored by CCTV cameras for the safety and security of people and property. Automated software checks the camera images for incidents, such as intrusion, fire or a person falling, and alerts our security staff.

Number plates of vehicles at this gate are read automatically to check whether the vehicle is authorised.

No facial recognition is used.

Operated by: [[CUSTOMER_NAME]]

Questions, the full privacy notice, or to exercise your data protection rights: [[CUSTOMER_CONTACT]]

Part B: full notice

Who is responsible

[[CUSTOMER_NAME]] ("we") operates the CCTV cameras at this site and is responsible, as Data Fiduciary under the DPDP Act, for the personal data described in this notice. You can contact us at [[CUSTOMER_CONTACT]].

What personal data we process

  • Video images of people and vehicles within the cameras' view.
  • When a possible incident is detected: a still image, the date and time, the camera location, the type of incident and a short automatically generated description, which may describe what a person is doing or wearing.
  • At vehicle gates: the number plate of any vehicle that is not on our list of authorised vehicles. Number plates of authorised vehicles are not stored.

Why we process it

  • To protect people, premises and property, and to prevent and detect crime and unauthorised entry.
  • To detect safety hazards, such as fire, smoke, flooding or a person who has fallen, and to respond quickly.
  • To control vehicle access at our gates.
  • To investigate incidents and, where necessary, to establish or defend legal claims and to assist the authorities.

How the system works

  • Our cameras are connected to software running on a computer at this site. When the software sees activity, it sends a few reduced-size still images to an AI service, which identifies possible incidents.
  • When a possible incident is found, our security staff receive an alert with a still image on a web portal and on their phones.
  • The AI system does not record continuous video. It does not recognise faces, does not identify who you are and does not build profiles of individuals.
  • Automated results can be wrong. Our staff review alerts before acting on them.

Our service provider

We use Shinrai Vision, provided by [[LEGAL_ENTITY_NAME]], which processes this data on our behalf as our Data Processor. Images and alerts are analysed and stored on servers in India. Alert notifications to our staff's phones are delivered through Google Firebase Cloud Messaging, which may process the notification content (the type of incident, the camera name and the time, but no images) outside India.

How long we keep it

[[CUSTOMER_RETENTION_STATEMENT]]

Your rights

Under the DPDP Act you have the right to:

  • obtain a summary of your personal data that we process and of our processing activities, and the identities of the others with whom we have shared it;
  • have inaccurate or incomplete data corrected, completed or updated;
  • have your data erased when it is no longer needed for its purpose, unless the law requires us to keep it;
  • withdraw your consent, where we rely on consent;
  • nominate another person to exercise your rights in the event of your death or incapacity;
  • have your grievances addressed by us.

To exercise these rights, contact [[CUSTOMER_CONTACT]]. We may need to verify your identity before acting on a request. If you are not satisfied with our response, you may complain to the Data Protection Board of India.