CCTV Privacy Notice

WHO WE ARE
DSG Sons Group, Inc., together with its affiliates and related companies (collectively, “Gaisano Malls,” “we,” or “us”), is a personal information controller registered with the National Privacy Commission (NPC) under Republic Act No. 10173 (Data Privacy Act of 2012).


WHAT WE COLLECT
We collect images and video recordings of individuals within our premises, including entrances, lobbies, common areas, corridors, and parking facilities. CCTV cameras operate on a 24-hour, 7-day-a-week basis.

We do not install CCTV cameras in areas where a reasonable expectation of privacy exists, such as:

  • Restrooms and washrooms;
  • Fitting rooms or changing areas; and
  • Designated private spaces.


WHY WE COLLECT IT

We process CCTV footage for the following purposes:

  • To ensure the safety and security of our customers, tenants, employees, and visitors;
  • To protect property within our premises against theft, vandalism, or unauthorized access;
  • To assist in the investigation of incidents, accidents, or unlawful activities occurring on our premises; and
  • To comply with legal obligations, including cooperation with law enforcement and regulatory authorities.

Processing is carried out pursuant to the Data Privacy Act of 2012 based on legitimate interests and/or legal obligations of Gaisano Malls.


HOW LONG WE KEEP RECORDINGS

Recordings are retained for a period of 30 days from the date of capture, after which they are securely deleted or overwritten, unless:

  • The footage is relevant to an ongoing investigation, dispute, or legal proceeding;
  • Preservation is required by a lawful order from a court, tribunal, or regulatory body; or
  • Retention is otherwise required by applicable law.

Archived footage retained beyond the standard period is kept only to the extent necessary and for the duration required by the applicable legal obligation or proceeding.



WHO HAS ACCESS TO RECORDINGS

Access to CCTV footage is strictly restricted to authorized Gaisano Malls personnel and, where applicable, to the following:

  • Law enforcement agencies, upon presentation of a valid court order, subpoena, or written official request in connection with a criminal investigation;
  • Regulatory or government agencies with lawful authority to require disclosure; and
  • Legal counsel of Gaisano Malls in connection with ongoing or anticipated legal proceedings.

Gaisano Malls will not sell, lease, or otherwise transfer CCTV recordings to any third party for commercial purposes.



YOUR RIGHTS AS A DATA SUBJECT

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data:

  1. Right to be informed — You have the right to know how your personal data is collected and used, which this Notice fulfills.
  2. Right to access — You have the right to access a portion of footage in which you or your property appears, subject to identity verification and provided such access does not compromise the privacy of other individuals captured in the recording.
  3. Right to rectification — You have the right to rectify or correct any inaccuracy or error in your personal data.
  4. Right to Object — You have the right to object to the processing of your personal data where processing is based on legitimate interest, unless such interest is compelling or required by law.
  5. Right to data portability — You have the right to obtain a copy of your personal data in a structured format, where applicable. Gaisano Malls may charge a reasonable administrative fee to cover the costs of processing and providing a copy of the CCTV footage, in accordance with NPC guidelines.
  6. Right to erasure or blocking — You have the right to request the deletion or blocking of your personal data where its processing is unlawful or where retention is no longer necessary.
  7. Right to damages — You have the right to be indemnified for any damages suffered due to the inaccurate, incomplete, or unauthorized use of your personal data.
  8. Right to file a complaint — You have the right to file a complaint with the NPC if you believe that your data privacy rights have been violated in connection with the processing of your personal data through our CCTV systems.

The exercise of these rights is subject to applicable legal exceptions, including where access would prejudice law enforcement, national security, or the rights of third parties.



HOW TO EXERCISE YOUR RIGHTS

To make a data subject access request or any inquiry regarding this Notice, submit a written request to our Data Protection Officer containing the following:

  1. Your full name and a copy of a valid government-issued ID;
  2. The specific date, time, and location of the incident or footage you are requesting;
  3. The reason for your request; and
  4. If applicable, a copy of a police blotter, court order, or other supporting document.

Gaisano Malls will respond to your request within fifteen (15) days from receipt, in accordance with NPC guidelines.



UNAUTHORIZED REPRODUCTION OF FOOTAGE

Any unauthorized recording, reproduction, or distribution of CCTV footage from Gaisano Malls’ systems is strictly prohibited. Gaisano Malls reserves the right to take appropriate civil and criminal action against any person found to be in violation of this policy.



CHANGES TO THIS NOTICE

Gaisano Malls reserves the right to update this CCTV Privacy Notice at any time to reflect changes in applicable law, NPC issuances, or our internal practices. 



CONTACT US

For questions, concerns, or requests related to this Notice, please contact:

Data Protection Officer

4th Floor, GMall of Davao, JP Laurel Ave., Bajada

Davao City, Davao del Sur, 8000

09178541447

dpo@gaisano.ph



This notice is posted in compliance with Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission.