Chipotle
Video Surveillance (CCTV) Privacy Notice
LAST UPDATED: August 1, 2024
Chipotle Mexican Grill UK Ltd and its affiliates (collectively, "Chipotle") operate a video surveillance (CCTV) system. The system captures and records video but does not capture or record audio. The CCTV system is designed to protect individuals and Chipotle's facilities with the help of cameras installed on our premises. The CCTV system is used to ensure the safety of our employees, visitors, and guests, and secure Chipotle’s property and assets against various dangers, such as burglary, theft, and vandalism.
Chipotle may use the CCTV system to investigate noncompliance with Chipotle policies and procedures, potential criminal activities on or to Chipotle property, and other incidents or accidents that occur within or around our property. In certain situations, Chipotle may use the CCTV system to preserve or hand over evidence of such incidents or accidents where required by law or compelled by lawful process.
This Privacy Notice describes how personal data of visitors, guests, employees and other individuals might be collected and used through the CCTV system. "Personal data" is information that identifies an individual or relates to an identifiable individual. Chipotle in Chipotle Mexican Grill UK Ltd and the local Chipotle entity using the CCTV system are the companies responsible ("data controllers") for the CCTV monitoring and the collection and processing of Personal Data through the CCTV system.
Chipotle may update this Privacy Notice from time to time and may notify you of such updates by any reasonable means, including by posting the revised Privacy Notice online. The "LAST UPDATED" legend above includes the date when the Privacy Notice was last revised.
For any questions regarding the CCTV system and this Privacy Notice, please contact us as indicated at the end of this Privacy Notice.
1. Applicability of Other Chipotle Policies & Procedures
For employees and contractors, this Privacy Notice supplements Chipotle’s European Employee Privacy Notice and other relevant policies and procedures. For visitors, guests, and other individuals this Privacy Notice supplements Chipotle’s European Privacy Policy (www.chipotle.co.uk/privacy-notice, https://www.chipotle.de/privacy-policy, https://www.chipotle.fr/politique-confidentialite), and other relevant terms and conditions.
2. Personal Data Processed
The Personal Data that may be collected and processed for the CCTV purposes include video recordings of you (i.e., your image as captured on the CCTV). The CCTV does not include does not include a “Facial Recognition or Analysis System” meaning automated biometric security or surveillance system that analyzes or uses depictions or images, descriptions, recordings, copies, measurements, or geometry of or related to an individual’s face to generate an output.
3. Purposes of Processing
Personal Data will be collected and processed for our legitimate business interests, to comply with legal obligations, or to protect the vital interests of our customers and employees, including:
· Maintaining the safety and security of Chipotle’s employees, visitors, guests, and Chipotle's property and assets;
· Safeguarding Chipotle's legitimate interests, such as investigating noncompliance with Chipotle's policies and procedures, potential criminal activities (e.g., suspected theft of company or personal property), and other incidents or accidents in the workplace;
· Initiating disciplinary and judicial processes and procedures, including preserving evidence and disclosing recordings for the purpose of legal claims and proceedings (although the systems won’t be used to continuously monitor employees' efficiency or task performance), Chipotle won’t ignore obvious improper or illegal activity captured through CCTV);
· Responding to requests from the individuals captured by the CCTV system to exercise their rights under applicable data protection laws or a person acting of their behalf.
4. Your Rights
You may request to access or delete personal data that the CCTV system collects about you, or object to the processing of Personal Data by the CCTV system, to the extent these rights are provided to you by applicable law. For example, if our processing is based on our legitimate interests, you can object to that processing. You can do so by contacting us as indicated at the end of this Privacy Notice. We will respond to your request in a manner that is consistent with applicable law.
To ensure that Chipotle can process your request, you may be required to provide Chipotle with the following:
· Adequate information for the recordings to be located, including when (within a one-hour timeframe) and where the CCTV recording took place; and
· Sufficient information (e.g., identification document or identification in person) to enable Chipotle to verify that you have a legitimate right to request access, correction, suppression, restriction, or deletion, or object to the CCTV processing.
Additional information for the European Economic Area (EEA), where applicable: you have the right to lodge a complaint to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. Contact details for data protection authorities in Europe are available at Data Protection Authorities - European Commission (europa.eu). Certain supervisory authorities will require that you exhaust our own internal complaints process before looking into your complaint. You may also contact our data protection officer (DPO) at privacy@chipotle.com.
5. Recipients & Disclosures of Personal Data
Personal data may be disclosed to:
· Chipotle’s affiliates;
· Chipotle’s service providers, such as the manufacturer and/or provider of the CCTV system; and
· Parties or entities who have the legal authority to compel us to disclose.
We may also use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law (which may include laws outside your country of residence), to respond to requests from government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons; (b) to enforce this Privacy Notice; and (c) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others. In addition, we may use, disclose, or transfer your personal data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
6. Data Transfer
Personal Data may be transferred to other countries that have a different data protection regime than the one that is currently found in the country where you are based, including the United States. In the EEA this may include countries outside the EEA. Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. Where we transfer your personal data to countries or organisations outside of the EEA which have been formally recognised as providing an adequate level of protection for Personal Data, we rely on the relevant adequacy decisions and regulations. Where the transfer is not subject to an adequacy decision or regulation, we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Privacy Policy and applicable laws. These safeguards are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021 under Article 46(2), including the UK Addendum permitted under Article 46(2) of the UK GDPR for the transfer of personal data originating in the UK and the Swiss modifications to the Standard Contractual Clauses for the transfer of personal data originating in Switzerland.
7. Data Retention & Security
Chipotle will retain CCTV footage for as long as is permitted by applicable law to enable the Company to fulfill the purposes outlined above.
The criteria used to determine a longer retention period include: (i) whether there is a legal obligation to which we are subject; or (ii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
Chipotle will take appropriate technical and organizational measures to protect your Personal Data, including requiring third-party service providers to use appropriate measures to protect the confidentiality and security of Personal Data.
8. Contacting Us
If you have any questions about this Privacy Notice, please contact us at the following email address
privacy@chipotle.com or by registered mail or post at the following addresses:
In the European Economic Area:
Chipotle Mexican Grill France SAS
6 place de la Madeleine
75008 Paris France
In the United Kingdom:
Chipotle Mexican Grill UK Ltd
83 Baker Street
Marylebone, London W1U 6AG