Supplier of LPG Gas and Autogas in Malta

1. INTRODUCTION

This Privacy Statement is applicable to the processing by Liquigas Malta Limited, based at Kalafrana, Birzebbugia (hereafter referred to as “Our Company”, “our”, “we” or “us”) of all personal data belonging to consumers, customers, suppliers and business partner data (“Business Partner Data”). This Privacy Statement is not applicable to business related data and/or data on companies.

Our Company is the controller for the processing of Business Partner Data. In this statement we describe who we are, how and for which purposes we process your personal data and all other information that may be relevant to you. In case you have any additional questions, you can contact us via the contact details provided at the bottom of this statement.

Our Company (the data controller) undertakes to comply with the provisions of the Maltese Data Protection Act (Chapter 586 of the Laws of Malta) –  and any other relevant legislation which is applicable to us in so far as you are concerned, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – the ‘GDPR’ as well as any subsidiary legislation issued thereunder (all the above, as may be amended from time to time, collectively referred to as the ‘Data Protection Laws’).

This Privacy Statement applies since 15 May 2018. The last modifications were made on 01/06/2023. This statement may change over time and the most up-to-date version is published on our website. If significant changes are being made, we will actively inform you.

 

2. DATA CONTROLLER AND DATA PROTECTION OFFICER

The Data Controller of your personal data is Liquigas Malta Ltd., Kalafrana, B’Bugia BBG 3011, Malta.

The Data Protection Officer (DPO) can be contacted at the followings email address: stephenlmuscat@liquigasmalta.com

 

3. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
Our Company will process your personal data when you do business with us, when you use our websites or apps or when you interact with us, as explained in further detail below.

A. For answering your questions
If you get in touch with us, we will use your personal data to reply and answer your question(s).

For this purpose:

      • we process your personal data based on necessity for our performance of a contract with you when you provide us with your personal data.
      • we process your name, contact details, your correspondence with us, your question, and all other personal data that you may have provided to us when getting in touch, which are necessary to answer your question.

B. For the development and improvement of products and/or services
We process your personal data to assess, analyze and improve our products and (customer) services. We use aggregated personal data to analyse customer behaviour and to adjust our products and services accordingly. When you use a Website or the App, enter or search data through this Website or the App; we also process your personal data to compile analytics reports. We use aggregated personal data to analyse customer behaviour and to adjust our products and services accordingly, to ensure that it is relevant to our customers. This means that we analyse how often you read our newsletters, how often you visit our Website or Apps, which pages you click on and what goods you purchase through our Website or Apps. We may purchase supplementary data from public sources to complement our database for the above purposes.

For this purpose:

      • we process your contact details such as your address, you telephone number and email address, personal details such as your name and date of birth, payment and credit information, and correspondence with us based on the necessity of our legitimate interest to develop and improve our products and services.
      • we process the personal data you may have entered into a Website or that were generated by the functionalities you used in a Website and the technical data from your device such as its IP-address, the pages you visited on our Websites, your click- and surf behavior and the length of your session based on your consent if you accept the respective analytics cookies when visiting our Website.
      • if you choose to participate in our surveys, we may ask you to provide us with personal data. such as your address, you telephone number and email address, personal details such as your name, gender (male/female/other) and date of birth. We may also use the personal data that you have provided in the survey for this purpose. Given that such surveys are completely voluntary, such processing would be based on your consent.

For more detailed information including what cookies are and how and why We process such data in this manner (including the difference between essential and non-essential cookies) please read Our detailed but easy-to-read Cookie Policy at https://liquigasmalta.com/privacy-cookies-policy/.

C. For the assessment and acceptance of a customer, supplier or business partner
When you get in contact with us, we will process your personal data, such as your name, surname, address, email address, telephone number, ID card details, date of birth and credit information and details of your correspondence with us for assessment and acceptance purposes, for example to confirm and verify your identity.

For this purpose:

      • we process such personal data because this is necessary for the conclusion of a contract between you and us. Our Company cannot enter into contracts without obtaining the required information.

Our Company will further process your personal data such  for other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists.

For this purpose:

      • we process such personal data on the basis of our legitimate interests for the detection and prevention of fraud.
      • we also process such personal data on the basis of our legal obligations, for example, when we are compelled to comply with anti-money laundering legislation.

D. For the conclusion and execution of agreement and relationship management
When you have purchased a product or service from us as a customer, or when you work together with us as a supplier or business partner, we process your personal data such as your name, surname, address, email address, telephone number, ID card details, date of birth and credit information and details of your correspondence with us to provide customer services, perform account management and communicate recalls, as well as for administrative purposes such as sending invoices and making payments. We also use your personal data to deliver or receive and administer our or your products or services. Our Company will process your personal data to further execute our agreement, including for the delivery of customer services. If, as a Business Partner, you are allowed to drive and use our Company’s vehicles, the personal data we process, in addition to the above, are your driving licence information, your A.D.R. (Agreement concerning the International Carriage of Dangerous Goods by Road) certificate data, your insurance details and information required to manage the vehicle lease contract.

For this purpose:

      • we process personal data because this is necessary for the conclusion of a contract between you and us. Our Company cannot enter into contracts without obtaining the required information. In some instances, we may also have a legal obligation to communicate with you and/or otherwise process your personal data, such as when informing you of recalls.

When you require access to Our Company’s premises, we also process your personal data for screening purposes on the legal basis of our legitimate interests to ensure the security of our premises and personnel.

For this purpose:

      • we process your contact details such as your address, telephone number and email address, personal details such as your name and date of birth, ID card detail, payment, order history and your visiting history to our premises.

E. For marketing via our newsletters
We use the information stored in our customer database to send you suitable offers and newsletters.

For this purpose:

      • when sending you newsletters and/or other relationship management and marketing communications, we process personal data based on your consent.
      • we process your contact details such as your address and email address, personal details such as your name, contact preferences, payment information, order history and correspondence with us.

Please note that even if you withdraw any consent, you may have given us or if you object to receiving such direct marketing material from us (in those cases where we do not need your consent), from time to time we may still need to send you certain important communications from which you cannot opt-out.

F. For business process execution and internal management
We process your personal data in the performance and organization of our business. This includes general management, order management and management of our assets. Our Company also processes your personal data for its internal management. We provide central processing facilities to work more efficiently. We conduct audits and investigations, implement business controls, and manage and use customer, supplier and business partner directories. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution.

For these purposes:

      • we process such personal data based on our legitimate interest to maintain and improve sound business operations and in some instances also based on our legal obligations.
      • the personal data we process are your contact details such as your address, telephone number and email address, personal details such as your name, date of birth, ID card number, payment and credit information, payment and order history, correspondence with Our Company and data generated during the performance of the agreement between you and Our Company.
      • if, as a Business Partner, you are allowed to drive and use our Company’s vehicles, the personal data we process , in addition to the above, are your driving license information and A.D.R. (Agreement concerning the International Carriage of Dangerous Goods by Road) certificate data, information required to manage the vehicle lease contract and information related to the use of the Company’s vehicle including speeding tickets, telematics data such as vehicle data regarding route, speed, acceleration, breaking, turns, functioning of the vehicle and on-board camera imagery.

G. For organizational analysis and development, management reporting and acquisition and divestures
At Our Company, we process your personal data (as described below) in the preparation and performance of management reporting and analysis. We use aggregated/anonymised personal data to create management reports and to analyse our business. We conduct customer, supplier and business partner surveys to learn more about your views and opinions in preparation of our management reporting. We also process your personal data for management reporting purposes in the context of mergers, acquisitions and divestitures and to manage such transactions.

For these purposes:

      • we process personal data based on our legitimate interest to maintain and improve sound business operations and to ensure business continuity.
      • we process your contact details such as address and email address, personal details such as your name and date of birth, payment and order history, correspondence with us and the information you provide when responding to our surveys.

H. When you use our websites and apps
If you use our Website, we process technical data to offer you our Website’s functionalities and to allow our Website’s administrators to manage and improve our Website’s performance. If you enter data in our Websites, such as a product preference or your location to receive relevant information or functionalities, Our Company processes this data to provide you with the requested information or functionalities. Further, we process your personal data to allow you to save your data (such as preferences and products) to your saved items and to allow you to share these with others using the sharing options you have configured on your device.

For these purposes:

      • we process personal data based on our legitimate interest to offer technically adequately working Websites and to improve our Websites’ performance with regards to essential cookies (for which we do not require your consent) and based on your consent if you accept the respective preferences cookies when visiting our Website
      • we process the personal data you have entered into our Websites or that is generated by the functionalities you have used in our Websites and the technical data from your device such as its IP address, the internet browser you use, the pages you have visited on our Websites, your click- and surf behavior and the length of your session.

For more detailed information including what cookies are and how and why we process such data in this manner (including the difference between essential and non-essential cookies) please read our detailed but easy-to-read Cookie Policy  at https://liquigasmalta.com/privacy-cookies-policy/

I. To allow you to connect with us
Our Company is active on social media platforms like Facebook, LinkedIn and Instagram. When you contact Our Company via social media, we process your personal data to answer your questions and to respond to your messages.

In addition, when you visit a ‘Connect with us’ screen on one of our Websites or Apps, you can contact us through a variety of communication channels. We provide you with our email address, for you to send us your feedback and suggested improvements, as well as our Website, trade website, and YouTube details. When you click one of the corresponding icons we will refer you to the website or app of the applicable third party, whether this is your email provider or a social media platform.

For these purposes:

      • we process personal data based on our contractual necessity to adequately respond to your questions and correctly refer you to our social media pages.
      • we process the communication channel you have chosen to use to connect with us and the personal data you supply to Our Company. This includes your (user) name, address, email address, telephone number and the personal data you have included in your message. In addition, when you click one of the buttons displayed, the relevant third party might place cookies on your device. Links that Our Company provides to third-party websites are clearly marked and we are not in any way whatsoever responsible for (nor can we be deemed to endorse in any way) the content of such websites (including any applicable privacy policies or data processing operations of any kind). We suggest that you should read the privacy policies of any such third-party websites.

J. To monitor and investigate compliance
We monitor our processes to check compliance with our policies and regulations. During monitoring activities, your contact details and personal data such as your name, surname, address, email address, telephone number, ID card details, date of birth and credit information and details of your correspondence with us may be accessed and viewed.

If, as a Business Partner, you are allowed to drive and use our Company’s vehicles, in addition to the above, your driving licence information and A.D.R. (Agreement concerning the International Carriage of Dangerous Goods by Road) certificate data, your insurance details information required to manage the vehicle lease contract and information related to the use of the Company’s vehicle including speeding tickets, telematics data such as vehicle data regarding route, speed, acceleration, breaking, turns, functioning of the vehicle and on-board camera imagery may be accessed and viewed.

For this purpose:

      • we may process your personal data based on our legitimate interest to monitor our internal processes for the detection and prevention of fraud and our legal obligations to comply with the law.
      • any personal data that is stored in our systems may be accessed and viewed for compliance purposes. The personal data that are accessed and viewed will not be stored for compliance purposes, unless we need them to further investigate potential non-compliant behaviour.
      • we do not retain your personal data for this purpose, unless they are linked to non-compliant behaviour. We will then retain the relevant personal data until the investigation or proceedings have been concluded.

K. To protect health, safety, security and to ensure integrity
At Our Company, we value your health, safety, security and integrity highly. We process your personal data to safeguard our employees, customers, suppliers and business partners. As such, we authenticate your access rights to our premises and may screen your personal data against publicly available government and/or law enforcement agency sanctions lists. We also process your personal data to protect Our Company and employee and customer assets.

For these purposes:

      • we may process your personal data based on our legitimate interest to monitor our internal processes and our necessity to comply with our legal obligations
      • we process your contact details such as your address and email address, personal details such as your name and date of birth, payment and order history, and your visiting history to our premises.

To safely deliver our product, our company uses vehicle technology to know where its tracks are located at any given moment for environmental and health and safety purposes, promoting safe driving for public security, protection of property (tracking stolen trucks for malicious purposes), for efficient driving and a reduction of CO2 emissions. This is particularly relevant if you are a Business Partner allowed to drive and use our Company’s vehicles.

For these purposes:

      • we process information required to manage the vehicle lease contract and information related to the use of the Company’s vehicle including speeding tickets, telematics data such as vehicle data regarding route, speed, acceleration, breaking, turns, functioning of the vehicle and on-board camera imagery.

L. To comply with the law
In some cases, we process your personal data to comply with laws and regulations. This could, for example, be the case where tax or business conduct related obligations apply. To comply with relevant laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities.

For this purpose:

      • we process your personal data due to our necessity to comply with our legal obligations
      • we process your contact details such as your address, telephone number and email address, personal details such as your name and date of birth, payment information, payment and order history, and your chamber of commerce and VAT details and tax details.

M. When you participate in events or promotions
We send you emails with promotions and invitations to participate in events. If you choose to participate in one of these activities, we need your personal data to be able to announce and organise these. In addition, if you participate in any of these activities, we need your personal data to measure the response to events and/or promotions.

For this purpose:

      • we process personal data based on your consent. You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before withdrawal.
      • we process your name, surname, address, telephone number, email address and your entries in the relevant event.

 

4. HOW LONG DO WE RETAIN YOUR PERSONAL DATA

Our Company generally shall retain Business Partner Data only for the period required to serve the applicable business purpose, to the extent reasonably necessary to comply with an applicable legal requirement or as advisable in light of an applicable statute of limitations.

Promptly after the applicable storage period has ended, the Data shall be:

    • securely deleted or destroyed;
    • anonymized;
    • transferred to an Archive (unless this is prohibited by law or an applicable records retention schedule).

 

5. WHO HAS ACCESS TO YOUR PERSONAL DATA

Access to your personal data within Our Company
As a global organisation, data we collect may be transferred internationally throughout Our Company’s worldwide organisation. Your personal data may be exchanged with the group that Our Company belongs to, shareholders and associated companies. We exchange your data for administrative purposes and so that we can have a complete overview of your contacts and contracts with the group that Our Company belongs to. We may also exchange your data to offer you a complete package of services and products (see Section 3(C), 3(J), 3(K), 3(M)).

Our Company’s employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.

In some cases, your personal data may be transferred to a country that does not provide an adequate level of protection of personal data. However, Our Company has taken measures to ensure that your personal data is adequately protected as Binding Corporate Rules are applicable throughout the group that Our Company belongs to. “A copy of such Binding Corporate Rules may be obtained by emailing stephenlmuscat@liquigasmalta.com.”

Access to your personal data by third parties
The following third parties may have access to your personal data where relevant for the provisioning of their products or services to Our Company: insurance companies, IT suppliers, auditors, legal advisors, public authorities, service providers, transport and delivery service providers, emergency and maintenance service providers, payment service providers and consultants.

When third parties are given access to your personal data, Our Company will take the required contractual, technical and organisational measures (for example, the entering into of appropriate data processing agreements) to ensure that your personal data are only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law.

If personal data is transferred to a third party in a country that does not provide an adequate level of protection of personal data, we will take measures to ensure that your personal data is adequately protected, such as entering into EU Standard Contractual Clauses with these recipients.

In other cases, your personal data will not be supplied to third parties, except when required by law.

Other Authorized Disclosures
Without prejudice to anything contained in this Privacy Statement and in the interest of full transparency, we reserve the right to disclose (and otherwise process) any relevant personal data relating to you which we may be processing (including in certain cases relevant IP addresses) to authorized third parties in or outside the EU/EEA if such disclosures are allowed under the Data Protection Laws (whether or not you have provided your consent) including but not limited to:

      1. For the purpose of preventing, detecting or suppressing fraud (for example, if you provide false or deceptive information about yourself or attempt to pose as someone else, we may disclose any information we may have about you in our possession so as to assist any type of investigation into Your actions);
      2. in the event of Liquigas Malta Limited being involved in a merger, sale, restructure, acquisition, joint venture, assignment, transfer;
      3. to protect and defend our rights (including the right to property), safety, or those of our affiliates, of users of our website or even your own;
      4. to protect against abuse, misuse or unauthorized use of our website;
      5. for any purpose that may be necessary for the performance of any agreement you may have entered into with us (including the request for provision of services by third parties) or in order to take steps at your request prior to entering into a contract;
      6. to comply with any legal obligations such as may arise by way of response to any Court subpoena or order or similar official request for Personal Data; or
      7. as may otherwise be specifically allowed or required by or under any applicable law (for example, under anti-money laundering legislation).

 

6. HOW ARE YOUR PERSONAL DATA SECURED?

We have taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, and against all other forms of unlawful processing (including, but not limited to unnecessary collection) or further processing.

 

7. HOW CAN YOU EXERCISE YOUR PRIVACY RIGHTS?

Before addressing any request you make with us, we may first need to verify your identity. In all cases we will try to act on your requests as soon as reasonably possible.

As explained in the ‘HOW LONG DO WE RETAIN YOUR PERSONAL DATA?’ section above, we may need to keep certain personal data for compliance with our legal retention obligations but also to complete transactions that you requested prior to the change or deletion that you requested.

Your various rights at law include:

Your Right of Access
You may, at any time request us to confirm whether or not we are processing personal data that concerns you and, if we are, you shall have the right to access those personal data and to the following information:

      • what personal data we have,
      • why we process them,
      • who we disclose them to,
      • how long we intend on keeping them for (where possible),
      • whether we transfer them abroad and the safeguards we take to protect them,
      • what your rights are,
      • how you can make a complaint,
      • where we got your personal data from and
      • whether we have carried out any automated decision-making (including profiling) as well as related information.

Upon request, we shall (without adversely affecting the rights and freedoms of others including our own) provide you with a copy of the personal data undergoing processing within one month of receipt of the request, which period may be extended by two months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Your Right to Rectification
You have the right to ask us to rectify inaccurate personal data and to complete incomplete personal data concerning You. We may seek to verify the accuracy of the data before rectifying it.

Your Right to Erasure (The Right to be Forgotten)
You have the right to ask us to delete your personal data and we shall comply without undue delay but only where:

      • the personal data are no longer necessary for the purposes for which they were collected; or
      • you have withdrawn your consent (in those instances where we process on the basis of your consent) and we have no other legal ground to process your personal data; or
      • you shall have successfully exercised your right to object (as explained below); or
      • your personal data shall have been processed unlawfully; or
      • there exists a legal obligation to which we are subject; or
      • special circumstances exist in connection with certain children’s rights.

In any case, we shall not be legally bound to comply with your erasure request if the processing of your personal data is necessary:

      • for compliance with a legal obligation to which we are subject (including but not limited to our data retention obligations); or
      • for the establishment, exercise or defense of legal claims.

There are other legal grounds entitling us to refuse erasure requests although the two instances above are the most likely grounds that may be invoked by us to deny such requests.

Your Right to Data Restriction
You have the right to ask us to restrict (that is, store but not further process) your personal data but only where:

      • the accuracy of your personal data is contested (see the right to data rectification above), for a period enabling us to verify the accuracy of the personal data; or
      • the processing is unlawful and you oppose the erasure of your personal data; or
      • we no longer need the personal data for the purposes for which they were collected but you need the personal data for the establishment, exercise or defense of legal claims; or
      • you exercised your right to object and verification of our legitimate grounds to override your objection is pending.

Following your request for restriction, except for storing your personal data, we may only process your personal data:

      • where we have your consent; or
      • for the establishment, exercise or defence of legal claims; or
      • for the protection of the rights of another natural or legal person; or
      • for reasons of important public interest.

Your Right to Data Portability
You have the right to ask us to provide your personal data (that you shall have provided to us) to you in a structured, commonly used, machine-readable format, or (where technically feasible) to have it ‘ported’ directly to another data controller, provided this does not adversely affect the rights and freedoms of others. This right shall only apply where:

      • the processing is based on Your consent or on the performance of a contract with You; and
      • the processing is carried out by automated means.

Your Right to Object to Certain Processing
In those cases where We only process Your Personal Data when this is 1.) necessary for the performance of a task carried out in the public interest or 2.) when processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, You shall have the right to object to processing of Your Personal Data by Us. Where an objection is entered, the processing of data shall cease, unless We as data controller provide compelling and legitimate grounds requiring the continuation of the data processing which outweigh the objections You may have raised.

When your data is processed for direct marketing purposes, You have the right to object at any time to the processing of Your Personal Data, which includes profiling to the extent that it is related to such direct marketing.

For the avoidance of all doubt, when We process Your Personal Data when this is necessary for the performance of a contract, when necessary for compliance with a legal obligation to which We are subject or when processing is necessary to protect Your vital interests or those of another natural person, this general right to object shall not subsist.

 

8. CAN YOU WITHDRAW YOUR CONSENT?

Once given, you may always withdraw your consent. Please keep in mind that withdrawal does not have retrospective effect and the withdrawal of your consent is only possible in case you first have given your consent. Please contact us to withdraw your consent by using the contact details at the bottom of this Privacy Statement.

 

9. HOW TO LODGE A COMPLAINT?
If you have a complaint about the use of your personal data by Our Company, you can lodge a complaint via the contact details at the bottom of this statement. Besides lodging a complaint with Our Company, you are also able to lodge a complaint with your local data protection supervisory authority, which in Malta is the Office of the Information and Data Protection Commissioner. We kindly ask that you please attempt to resolve any issues you may have with us first (even though, you have a right to contact the competent authority at any time).

 

10. HOW CAN YOU CONTACT US?

If you have any questions about the way we process your personal data, please read this statement first. For additional questions, remarks, compliments or complaints, please contact us by telephone on +356 2248 6000, or by email at info@liquigasmalta.com.

CCTV Policy

Last updated on 27th of July 2023

 

1. Policy Statement

Liquigas Malta Limited (‘Liquigas’), as a data controller, uses CCTV (closed circuit television) throughout its premises, to provide a safe and secure environment for employees of Liquigas and for any visitors to the premises and to protect the property on the same site.

The scope of this policy is to define a proper procedure for the use of CCTV and to detail the controls necessary to ensure compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data – the ‘GDPR’ and the Data Protection Act (Cap. 586 of the Laws of Malta) as well as all subsidiary legislation issued thereunder (as may be amended from time to time). These laws shall hereafter be collectively referred to as ‘Data Protection Laws’.

Liquigas has produced this policy in line with the Guidelines on processing of personal data through video devices as published by the European Data Protection Board (Guidelines 3/2019) and adopted on 10 July 2019. Such Guidelines reflect the principles enshrined in the Data Protection Laws.

 

2. Purpose

The CCTV system will monitor strategic locations on the premises in which Liquigas operates, primarily at the perimeters, entrances and exit points of all buildings, covering both public and non-public spaces with the purpose to:

    • Deter crime;
    • Protect the health and safety of employees and visitors on the site;
    • Monitor the security of the site and property thereon.

Whereas the CCTV system is in place for all of these purposes, Liquigas personnel will not always be monitoring for all of these purposes all of the time.

 

3. Responsibilities

Liquigas, in relation to the CCTV system, will have the responsibility to:

    • Ensure compliance with the Data Protection Laws with reference to the operation and use of CCTV equipment and the recording and viewing of images;
    • Ensure that the monitoring of CCTV systems is conducted for all applicable locations, and in compliance with applicable legislation and the Company’s (Liquigas) policies (including but not limited to the Liquigas Master Privacy Policy available on Liquigas’ website or in paper form upon request);
    • Ensure that the system is maintained and repaired when necessary;
    • Deal with any complaints regarding the operation of the CCTV system;
    • Deal with any requests regarding the CCTV system by the data subjects;
    • Deal with any requests regarding the CCTV system from public authorities and the police;
    • Retain images for evidential purposes and ensure they are kept in a secure place to which access is controlled.
    • Monitor the entrance and exits of Liquigas’ premises.

 

4. Users

    • Liquigas’ security staff, logistics and distribution manager and customer care staff (the ‘Users’) are allowed to carry on the monitoring of live images (for security purposes stated in section B above).
    • Liquigas’ security staff and senior management (the ‘Users’) are allowed to carry on the monitoring of live images and reviewing the recordings of the images at all times (for security purposes stated in section B above).

 

5. Actions for the Implementation and Development of the Policy

The principles of operation of the CCTV system are:

    • The system will only be used in a lawful and fair manner.
    • The recording medium will be overwritten and any copies destroyed after 7 days unless required as evidence in Police or internal investigations and proceedings. In such cases, the recordings shall be kept until the investigation is concluded and shall be destroyed once they are no longer necessary.
    • An incident reporting procedure shall be in place ensuring the logging of every occurrence including requests to access, retain and/or have a copy or extract of the recording, both submitted internally (e.g. employees) and externally (e.g. law enforcement agencies).
    • On removing the medium on which the images have been recorded for use in legal proceedings, the Users will ensure that there is documentation of:

a) The date on which the images were removed from the general system for use in legal proceedings;

b) The reason why they were removed from the system;

c) Any crime incident number to which the images may be relevant;

d) The location of the images;

e) The signature of the collecting Police Officer or other Government agent where relevant.

    • Signs will be placed so that the employees and the visitors on the site are aware that they are entering a zone which is covered by surveillance equipment. The signs are clearly visible and legible.
    • Every access to recordings should be justified and a record (audit trail) including the reason for accessing such recordings will be kept.
    • All Liquigas staff shall familiarise themselves with this CCTV Policy (and other Liquigas policies that have been made available) and take all measures to fully comply with the same and the Data Protection Laws.
    • Any individual whose personal data are held by Liquigas in the form of a CCTV recording can request access to that recording under certain conditions and Liquigas will respond in accordance with the Data Protection Laws. Such request will be evaluated by the Users and/or other authorised person(s) of Liquigas responsible for data protection who will provide without excessive delay and without expense, written information as required by law. Where required to be provided, the information shall indicate, in particular:
    • The actual personal data which are processed;
    • The source of the information;
    • The purpose of the processing;
    • Any recipients or categories of recipients of the data;
    • The applicable retention period;
    • The various rights to which the data subject is entitled under the GDPR (including the right to rectification, erasure and restriction -where applicable as well as the right to lodge a complaint with the Maltese Office of the Information and Data Protection Commissioner);
    • As well as any other information to which the data subject is entitled under Article 15 of the GDPR (Right of Access).

 

In such cases, only information concerning the individual specifically making the request may be provided. Other information revealing the identity of other persons should not be disclosed. In the case of an ongoing investigation, whereby providing information may be prejudicial to the investigation itself or to the rights and freedoms of others, such information could be withheld.

Although the law does not specifically entitle the individual to have an extract of the images being recorded, or to view directly the images, in the case of CCTV systems, the most practical approach is to invite individuals for direct viewing of the images, provided that the identity of third parties is obscured. If an individual is not satisfied with the reply provided, or with the manner by which access is granted, the matter may be referred to the Information and Data Protection Commissioner who will investigate the case and ascertain that the right of access is properly granted.

    • Liquigas may release recordings to the Police or other authorities empowered by law to request the information, for the purposes of prevention or detection of crime, the apprehension or prosecution of offenders, or in the interests of national security, or in other circumstances where Liquigas is legally obliged to do so, or in accordance with the specified purposes of the CCTV system.
    • Where individuals appearing in the footage, are third parties to an investigation or a request for access, and their images are not considered relevant, these shall be obscured. In cases where images identifying third parties are relevant to an investigation, the identity of these persons may be disclosed strictly for the purposes of the investigation itself (e.g. to prove their innocence) and should be retained only until the investigation is concluded.

 

6. Further Information

For more detailed information on how the data subject’s personal data are processed, please read the Liquigas Privacy Policy which can be accessed on https://liquigasmalta.com/privacy-statement-for-business-partner-data/ or ask for a printed copy at the address cited below.

For further information relating to this policy and the procedures concerning the use of CCTV cameras, employees and other individuals are to contact the Liquigas security staff.

 

LIQUIGAS (the Data Controller)
Kalafrana, Birzebbuga, Malta
Tel: (+356) 22486010
Email: info@liquigasmalta.com

 

In addition, for matters or enquiries relating to data protection, individuals may wish to contact the Information and Data Protection Commissioner on the details provided below:

Office of the Information and Data Protection Commissioner
2, Airways House, High Street
Sliema, SLM 16

Tel: (356) 2328 7100
Fax: (356) 2328 7198