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Surveillance policy (SL, OA+)

Purpose

The purpose of this policy is to outline guidelines for the use of security cameras in operational hubs to ensure the safety of employees and the protection of company assets and property. It also defines the access controls and procedures for requesting camera footage.

Scope

This policy applies to all security cameras installed in Flink operational hubs, as well as to all employees, contractors, and third-party personnel working on or visiting the premises.

Policy statement

Camera placement

Cameras shall be installed in locations that protect against theft, especially for high-value assets. Specifically, cameras should focus on the following areas:

  • Entrances and exits: to monitor unauthorized entry and safeguard high-value equipment, such as computers and laptops.

  • Bike storage: high risk areas with a history of theft.

  • The battery cabinet: for visibility in case of fire.

Access to camera footage

To maintain privacy and ensure the responsible use of video footage, access is restricted as follows:

Authorized access:

  • During operational hours: only the Head of Country Operations and the QHSE Lead, along with a City Manager, may access camera recordings in the event of incidents. This follows the "four-eye principle".

  • During non-operational hours: Securitas has the authority to log in and view surveillance footage. They serve as a second layer of verification during non-operational hours and can notify emergency services in cases of fire or break-ins (refer to the Securitas flowchart for further details). The QHSE Lead may also access camera footage under the following circumstances:

    • Suspected technical issues with the alarm system or unexplained triggers during non-operational hours

    • Suspected incorrect use of the system,such as during bakery deliveries outside of operational hours.

  • Audits: during audit rounds the QHSE may check camera positions to ensure they are operational and correctly aligned.

  • Incident-based access requests: City Managers may request access to specific footage only in cases of documented incidents such as:

    • Theft or vandalism

    • Employee injury or accident

    • Unauthorized access or security breaches

    • Safety hazards or operational disruptions

    • Unexplained alarm triggers

  • A written request must be submitted via the Slack workflow in #nl_regional_operations to the Head of Country Operations and People Partner specifying:

    • The date and time of the incident.

    • The location or camera number (if known).

    • A brief description of the incident.

  • The Head of County Operations and People Partner can review the request upon validation, and provide the necessary footage for investigation purposes. Access is granted only on a need-to-know basis to the relevant City Manager and involved parties.

Important:

Unauthorized personnel, including City Managers and operational staff are prohibited from accessing camera footage under normal circumstances.

Data retention and privacy

Video footage is used strictly for security, safety, or the investigation of incidents.

Employee privacy is paramount, and camera footage will not be used for performance monitoring or any form of surveillance unrelated to safety and security.

Data retention and evidence preservation

The recordings are stored for a maximum of 7 days. After that, they’re automatically deleted.

In case a crime or substantiated suspicion of a crime has been established, only the relevant recording (limited to the section of the crime) is saved for the purpose of preserving evidence.

Cloud storage and security

The recordings are stored in the password-protected cloud of the camera provider. The provider acts as an instruction-dependent order processor for Flink. We have a contract with them for order data processing.

Cameras are not accessible via open ports or the internet connection on-site.

References

Read more about surveillance/Securitas here

For HM/RM's: read the surveillance/Securitas policy here

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