Frontline Privacy Notice (“Notice”) This Privacy Notice addresses how Frontline Security Solutions Limited and Frontline Systems Limited, Littleton Road, Ashford, Middlesex TW15 1TZ (“Frontline”) may collect and process personal information from you, separate and apart from its websites and mobile applications. The privacy notice for the Frontline website is available on that particular website. Frontline interacts with individuals in a variety of ways: employees of Frontline customers, contact persons of Frontline customers and end users of Frontline products and services. To enable these interactions, Frontline is collecting and processing personal information. Frontline has implemented technical, organizational, administrative, and physical measures to safeguard any personal information Frontline may process. As this Notice is intended to cover a variety of situations, some information in this Notice may not apply to you. This Notice may be modified from time to time without prior notice. Please review this Notice on a regular basis for any changes. The effective date of the current version appears at the end of this Notice.
What personal information might Frontline collect? The personal information that Frontline collects is subject to applicable legal and contractual requirements. Because this Notice covers a wide variety of situations, there may be data elements listed here that do not apply to your specific situation. Please contact Frontline if you have any questions.
Type of personal information
- Name and salutation (such as Mr. or Mrs.)
- Emergency contact information
- Work contact information, including telephone number, email address, mailing address, and work location
- Home address, personal email address and home telephone number, including personal mobile telephone number
- Information about an individual’s employer, including company name(s), company location(s), company address(es), and country of incorporation
- Job title, department and job function Visitor information, including the time of arrival and departure, date, name visitor, name company, location of visits, information regarding the vehicle for parking purposes, information required for a badge (which may include a photograph), visitor’s signature and information necessary to maintain visitor logs and screening.
- Payment and invoice-related information, including identification and bank account numbers
- Information collected through a voluntary survey or promotional campaign Record of any incident that occurs while on Frontline premises
- Information that may be collected as part of the execution of the contract, such as time and attendance data, badge information, photographs, audio, video, or geolocation data used for a particular role or assignment Government-issued identification numbers (in whole or in part), such as a tax identification number, VAT number
- Information provided to facilitate a service or request assistance, such as product use or problem information Information required to process a claim or any information that a person chooses to include in a document that is part of a legal proceeding involving Frontline
- Live video images when responding to alarm triggering events, and audio recordings. Live video images and telephone recordings.
- In case of IP connections with the Frontline alarm center: IP addresses are stored. In case of Frontline’s Tracking & Tracing services: location is stored. In case of Frontline’s video services: username / password, IP addresses and video images are stored. For the Alarm Processing System: the log book is stored (and in some cases access information). In case of monitoring of (ex) prisoners: criminal background info might be stored.
- Information regarding health and injuries, such as disability, sickness, accident related info, and other related information that may be part of video images, recorded conversations, and actions linked to responding to alarm triggering events
How might FRONTLINE use the personal information it collects?
- Conducting regular business operations, including designing and developing products, managing an Enterprise Resource Planning (ERP) system, sending invoices and collecting payment, providing payment, and providing goods and services to customers, which may include sharing limited personal information with customers or other business partners
- Providing requested products and services, which may include use of geolocation for certain applications in a known and transparent manner. Providing details and information about other products and services that can be supplied.
- Managing communications and notices
- Managing physical security, including access controls and security, facility access and safety, and disaster preparedness
- Responding to alarm triggering events
- Overseeing location tracking, duration, and other telematics of certain Frontline assets and applications for management of services provided, security, safety, and efficiencyEnsuring compliance with import, export, and other international trade controls, including screening for sanctioned or restricted countries or parties
- Performing audits and compliance reviews to ensure compliance with applicable policy, regulation, and law
- Conducting and managing internal and external investigations, including Legal, Global Ethics & Compliance, and International Trade Compliance reviews and any resulting disclosures to government agencies
- Evaluating and reporting conflicts of interest
- Addressing environmental, health, and safety issues, including injury and damage claims
- Prosecuting and defending claims in litigation, arbitration, administrative, or regulatory proceedings, including but not limited to pre-dispute activity, evidence collection, discovery, litigation holds and e-discovery efforts
- Responding to law enforcement and other government inquiries
- Administering of marketing, contract, joint ventures, and other business efforts, including without limitation invoice and payment processing, project management, and customer surveys and promotions
- Designing, selling, producing, and improving products
- Providing customer service and support
- As required or expressly authorized by applicable law or regulation
- For training of Frontline employees and quality purposes of Frontline products and services The Alarm Processing System For alarm processing of incoming alarms (log book is stored and in some cases access information) National Response whereby a security agency is getting orders from Frontline (e.g. by checking on the location in case of an alarm) and whereby the name, address and telephone number of the customer can be provided
- Video platforms To be able to assess the video images In case of an alarm, Frontline employees and the local police can watch “live” video images For the contract administration and invoicing
- Tracking & Tracing application – For locating
- Teleservice application – For handling incoming messages at the teleservices
- Archive – For storage of the customer’s file
Responding to situations involving a risk of health or safety, including an emergency and accident
With whom might Frontline share the information it collects?
Frontline will not sell or otherwise share your personal information outside Frontline except to:
- APi group companies, on a strict ‘need to know’ basis (e.g. for internal audit purposes).
- APi group companies to enable them to offer you products or services, to include but not limited to Mentor Business Services Limited; Chubb Systems Limited; Chubb Ireland Limited; Security Monitoring Centres Limited; Frontline Security Solutions Limited
- service providers Frontline has retained to perform services on Frontline behalf. Frontline will only share your personal information with service providers with whom Frontline has signed a processing agreement except as necessary to perform services on Frontline behalf or to comply with legal requirements, including but not limited to in response to a legitimate legal request from law enforcement authorities or other government regulators;
- investigate suspected or actual illegal activity;
- prevent physical harm or financial loss; or
- support the sale or transfer of all or a portion of Frontline business or assets, including through bankruptcy.
Where does Frontline store your personal information?
Frontline stores your Personal Information in United Kingdom, Ireland and Europe. Personal Information may also be stored worldwide, however there are Binding Corporate Rules or Data Transfer Agreements in place should the information be shared. Further, for customer and visitor screening, the control is carried out via an automated database of one of Frontline’s service providers currently located in the United States. Frontline has signed a data transfer agreement with the service provider to guarantee the protection of the data.
How long does Frontline retain Personal Information?
Frontline retains personal information for the length of time required to fulfill the purpose for which it was originally collected and for any additional period as required by applicable law or regulation, court, administrative or arbitration proceedings, or audit requirements.
What choices do you have about how Frontline uses your personal information?
Frontline will use your personal information for executing its contractual obligations towards its customers and business partners. You will always have a choice about whether Frontline uses your personal information for direct marketing purposes. If you have provided Frontline with your personal information and would now like to request that it is no longer used for marketing purposes, please contact Global_privacy@chubbfs.com
How can you contact Frontline?
You have the right to lodge a complaint with the Information Commissioner’s Office. You also have the right to withdraw consent, to request access to and correction or erasure of your personal information, seek restrictions on or object to the processing of certain personal information, and seek data portability under certain circumstances. To contact Frontline regarding the above, please email Global_privacy@chubbfs.com
How can you contact Frontline?
If you wish to access, correct or update your personal information, or if you have questions about Frontline’s privacy practices in general or a complaint, please email Global_privacy@chubbfs.com
Last Updated: 22 February 2023