Camera Surveillance Protocol

This protocol applies to Denham The Jeanmaker B.V. (“Denham”). Denham is responsible for processing of the data and is therefore considered to be the data controller.

Purpose of this Protocol

This protocol sets out how Denham records, collects, uses and stores images of camera’s that are installed by Denham in and around its properties, offices and/or stores. Cameras are hereafter also referred to as: “CCTV”.

Objective of camera surveillance

Denham uses camera surveillance for:

  • Access control to properties, offices and stores;
  • Monitoring of Denham offices, stores, (prospect) customers, employees, suppliers and other visitors to guard against theft;
  • Security of Denham properties and offices, stores, its (prospect) customers, guests and its employees against unauthorized access and other unwanted activities (especially in unmanned locations);
  • It may register and identify unauthorized persons and persons who engage in other undesired activities.
  • everything that is directly related to it.

The use of camera images must align with the purposes set out above, unless necessary in the interests of preventing, investigating and prosecuting criminal offences.

The camera images should not be used to assess how employee’s function.

Responsible: The Retail Manager for CCTV in stores

Denham management has according the Procedure on camera systems which is part of the Privacy Policy of Denham appointed the Retail Manager to take overall responsibility for CCTV usage in the stores in accordance with the attached applicable (local) retention period and the legal requirements. The Data Privacy Officer or the employee responsible for privacy supervises the correct use of the camera images.

Responsible: The Human Resource Manager for CCTV in offices

Denham management has according the Procedure on camera systems (attached) appointed the Human Resource Manager to take overall responsibility for CCTV usage in offices of Denham. The Data Privacy Officer or the employee responsible for privacy supervises the correct use of the camera images. Location of the cameras is around the properties of Denham at Tt. Vasumweg 95 (1033 SG) Amsterdam.

When installing CCTV, Denham takes into account the following:

  • cameras are installed in places where they are visible to those involved and only in places where CCTV has proved necessary.
  • Denham does not use hidden cameras (it has placed CCTV-signs around the properties and the stores).
  • The cameras are not directed at public spaces unless this is unavoidable to protect the products and people that Denham oversees.
  • Cameras are not placed in places that are private, such as toilets, changing rooms and homes, or in places where Denham employees are mainly present, such as offices and canteens.
  • Only fixed cameras are installed. Denham does not use camera surveillance through drones, for example.
  • Facial recognition software is not used in camera surveillance.


It is Denham’s policy to inform those involved in advance of the processing of personal data. CCTV usage is explained via signs at the entrance to the property or building where the cameras are located, through this Protocol and by means of the Denham Privacy Policy.

All staff shall be informed prior to the Protocol coming into effect. This Protocol is part of the Denham Privacy Policy.

Legal basis for CCTV

The legal basis for using CCTV is that it is necessary for the legitimate (business) interest of Denham namely the security of visitors, customers, employees and property.

It has been established that Denham has no other less invasive capabilities than CCTV to secure the locations and/or buildings appropriately and that camera surveillance is part of a total package of measures.

Access and security of the images

Denham has taken adequate measures to protect the camera images. Denham ensures that camera images are appropriately protected against loss or any form of unlawful use. The camera images are protected. Access control and logging can determine who has accessed the camera images when accessed the camera images.

CCTV footage may only be seen after an incident or suspicion by authorized persons as set below.

Incidents include theft, burglary, vandalism, fraud, property damage, sabotage, (other) crimes, serious violations (of house rules), and events that put persons at risk or otherwise harmed.

Access to the camera footage in the event of (a suspicion of) an incident is limited to the following persons:

  • The Retail Manager and the Store Manager for the Denham stores of Denham.
  • The Human Resource Manager for the offices and the stores of Denham.
  • Employees of the IT company CTS-it and Denham HQ are responsible for securing safety of the stores and offices– this company and its employees are required to keep the camera images secret.
  • Members of Denham’s management.
  • The Data Privacy Officer or the employee responsible for privacy.

In principle, exceptions can be made if submission to third parties is necessary under a legal obligation or if a failure or maintenance of camera registration equipment makes this necessary. After use by the third party, the Retail Manager for stores and Human Resource Manager for the offices must ensure that any copies made are destroyed immediately.

Provision to the police and the judiciary

If there is an (alleged) crime, Denham is entitled to provide the camera footage to the police and/or the prosecuting authorities. The Data Privacy Officer or the employee responsible for privacy and the Management jointly will assess whether it is really necessary to provide the camera images.

Retention period of the images

After capture, camera images are retained for a maximum of seven days unless there has been an incident and the camera footage are used as evidence. A longer retention period may also be necessary if further investigation is required. The camera images will then be kept for as long as necessary in the context of incidents that occurred or as long as necessary for further investigation.

Rights involved

Those involved have the right to access images on which they are recognizable and to request the removal of the data, provided that the rights and freedoms of others are not violated. A request for this can be addressed to the email address: A request for access or retrieval of a copy requires a clear indication of the period on which the person believes that he has been filmed. Denham will respond to the person's request within four weeks.


Any complaints about how Denham handles personal data matters may be reported to or to Denham B.V. at the Tt. Vasumweg 95 (1033 SG) Amsterdam, The Netherlands. Complaints may also be lodged with the Dutch Data Protection Authority (the DPA) through this link