Privacy Notice for Body Temperature Scanning (BTS)

As a matter of public health and safety in preventing the spread of the novel coronavirus,  SARS-CoV-2, and COVID-19, and as a risk-based measure to protect you and all who enter or operate on our premises, we are lawfully and proportionately conducting BODY TEMPERATURE SCANNING (BTS) at the locations listed in section 12 below.

This Privacy Notice sets out the basis on which we process any personal data that we collect from you, or that you provide to us in relation to BTS. This Privacy Notice goes together with our terms of use and any other documents that we may have shared or agreed with you in relation to our contractual relationship- as your employer, commercial business partner, consultancy, etc. Please read this Privacy Notice carefully to understand our views and practices regarding your personal data and how we will treat it.

The body temperature scanner that we use is a thermal scanner.  It will be positioned at the entrance of the premises.  It uses a thermal hybrid network camera which is able to measure body temperatures without contact for up to 3 meters.  Facial recognition features will not be applied on the device and while snapshots of abnormal temperatures are taken, these will be immediately deleted.  No facial recognition biometric data will be collected or stored by the device.

DENSO will be what is known as the ‘Controller’ of the personal data you provide to us. When you enter our premises, a thermal camera will detect your surface body temperature, and indicate whether your surface body temperature is above a minimum threshold of 37.0 to a maximum of 37.5 degrees Celsius, depending on the location. Please note the relevant threshold which applies to your location. If your surface body temperature is within the risk-acceptable range, you may proceed as normal.

This body temperature data still falls into a specially controlled category, and we have therefore put appropriate measures in place to enable us to safely and legally process it. The BTS process has been risk assessed and your data will only be processed for the minimum period required to determine whether you may safely access and remain at these premises.

You provide us with your personal data by passing through the range of the BTS thermal camera.

If you contact us in relation to this, we may keep a record of that correspondence for a minimum period.  Please note that all of this is subject at all times to your full rights as Data Subjects (covered in section 10 below).  You may exercise your rights as a Data Subject at any time, including the deletion of your personal data, using this web form.

If the thermal camera indicates that your surface body temperature is above the threshold, we firstly ask for your cooperation and understanding. We will try to manage this situation as discretely and quietly as possible to avoid any undue attention to you. There may be perfectly normal reasons why your surface body temperature is above the threshold and we are not drawing any medical conclusions. This is purely a risk-based precaution.

We are processing this personal data because we have taken a risk-based approach to protecting the safety of everyone on our premises, in line with the relevant laws that apply.  In doing so, we balance both your right to privacy, and the legally permitted efforts to combat and control the spread of covid-19. A such, we are not seeking to measure your body temperature for medical reasons, or part of any clinical exercise.  This is simply a risk-based approach to minimise the likelihood that you or others are exposed to adverse health conditions, including covid-19.

We will only use your personal data (surface body temperature) from the BTS to determine whether you may safely enter the premises. This information will not be shared with any other third parties, unless we are legally required to do so. Furthermore, if we need to share your personal data because of a legal obligation we will inform you without delay, wherever we can legally inform you.

The personal data that we collect from you relating to your surface body temperature is processed only within the European Economic Area (EEA). This data will not be stored. It will only be viewed to make a real-time assessment regarding your safe access to the premises.

Your personal data from the BTS is processed real-time and not stored. The thermal scanner does not transmit your data and as such, there is no risk of your data being intercepted or accessed without proper authorisation.

Once we are in possession of your personal data, we will use strict procedures and security features to try to prevent unauthorised access. Only very limited and duly authorised representatives of DENSO can operate the thermal scanner and see your personal data. Such representatives are bound by high standards of confidentiality regarding your personal data.

Your personal data (body temperature) will not be stored.

If for any reason we are legally required to store any personal data relating to your scanned body temperature, in all cases, we will never keep your information longer that strictly necessary under (national or EU) law. We are processing BTS personal data only or for the execution of the activities and obligations arising from your business or contractual relations with DENSO (in this case, access to the premises).

As a Data Subject, you have certain rights and you may freely exercise them at any time by contacting us through this web form.  Below is a summary of your rights and what they mean from your perspective:

If you exercise a right, we will revert to you as soon as possible and complete it within 1 month, unless the request is exceptional. Please consider that we will be able to satisfy your deletion request only if and when we are not obliged to keep your information under national or EU legislation or reason of public interest.

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated: privacy@eu.denso.com .

Please remember that you can exercise your rights as a Data Subject at any time using this web form.

At all times, you have an absolute right to refer matters about how we use your personal data to your local Data Protection Authority: