Msite Privacy Statement

BAM Construct UK Limited (hereinafter: “BAM” or “we”) operates this website and other websites relating to BAM Construct UK Limited and its subsidiaries (together "BAM websites") and we are committed to protecting your privacy. This Privacy Statement covers the processing of personal data of BAM employees, visitors and suppliers on MSite by the means of biometric recognition technology, i.e. facial recognition.

BAM has provided below information on the collection of your personal data, together with information on how you can access your personal data.

BAM Construct UK Limited

Breakspear Park,

Breakspear Way,

Hemel Hempstead,

Hertfordshire,

HP2 4FL

The Privacy Officer for BAM Construct UK Limited can be reached at privacy@bam.com

BAM has implemented MSite facial recognition technologies to recognise individuals from a digital facial image. Biometric data will be collected from facial recognition cameras installed at the entry and exit points of BAM sites. Biometrics are unique biological identifiers that identify a particular individual. This includes scans of your facial geometry, retina and iris patterns.

Biometric data is collected through the MSite automated biometric recognition system, which uses electronic equipment to analyse the information from the individual and compare it to the information stored in the system to confirm if there is a match, and subsequently recognise or identify the individual. The biometric profiles are recorded and stored securely on the MSite system. Access to biometric profiles is restricted to MSite administrators and to those line managers who are authorised to access them in accordance with the purposes of the system. Records will be maintained detailing who has access to the data, details of dates and times access was granted and for what reason.

In addition to verifying your identity, our facial recognition technology automatically records your attendance and time of entry/exit from sites.

The data collected from this process will assist with the following:

• Verifying or authenticating your identity
• Detecting and preventing unlawful or unauthorised access
• Maintaining site access records for security and safety of personnel, visitors and suppliers, for example in the event of a fire we have an accurate attendance record
• Contactless time and attendance recording, eliminating the need for physical access keycards and hard copy timesheets
• Monitoring worker fatigue
• Reducing project costs by preventing fraudulent claims for hours worked
• Complying with statutory health and safety obligations
• Ensuring appropriate site induction processes are complied with
• Internal management, organisational analysis and sustainability reporting

The following basic information will be collected on the MSite enrolment system for your profile:

• Name
• Address
• Date of birth
• Contact details, i.e. email address, phone number etc
• Next of kin

In some instances, special category data may also be collected for example responses to optional diversity monitoring questions on ethnic origin, race, sexual orientation. 

Your personal data will be processed by the automated facial recognition system in order to: 

• Record your digital facial image as a biometric template, e.g. taking a facial scan,
• Store your biometric information on a database,
• Use your biometric data as part of an electronic process, e.g. by comparing it with biometric information stored on a database to identify or recognise you,
• Comply with legal obligations, such as the obligations under UK Data Protection Laws to meet certain conditions (or lawful bases) to demonstrate that our use of your personal data is necessary and proportionate. This includes biometric data, such as facial scans for facial recognition readers which grant access to our sites. 

The legal basis for processing your personal data for this purpose is your ‘consent’. By opting in for consent on the MSite enrolment system, you explicitly consent to the processing of your personal data for the purpose of your employment. You have the right to withdraw your consent at any time via your MSite profile or by emailing privacy@bam.com. If you withdraw your consent, this does not affect the lawfulness of processing based on consent before withdrawal.

You also have the right to choose an alternative method of site access, i.e. the MSite mobile application or an allocated PIN number. If you wish to amend your selection during the course of your employment, you can do so by emailing privacy@bam.com.

All biometric templates and personal data recorded on the MSite facial recognition system will be retained for the duration of your employment with BAM and in accordance with our retention schedules. When your employment at BAM ends and your account deleted from our systems, all biometric data linked to your account is also deleted accordance with our retention schedule.

Disclosure of personal data to other third parties will only be made in accordance with the purposes for which the particular system concerned is used and will include: 

• Technology operators, such as MSite
• Line managers or other authorised management involved with health and safety investigations, disciplinary or performance evaluation
• The police and other law enforcement agencies, where the data could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness
• Prosecution agencies, such as the Crown Prosecution Service.
• Relevant legal representatives
• Insurance companies
• Health support companies

All requests for disclosure and access to personal data will be documented, including the date of the disclosure, to whom data has been provided and the reasons why they are required. If disclosure is denied, the reason will also be recorded.

Under UK Data Protection Laws, individuals have the right on request to receive a copy of their personal data that the company holds about them. 
You can request access, correction, restriction, portability or removal of the data that BAM processes about you at any time by sending a request to: privacy@bam.com. 

If you added information to your BAM HR profile yourself, then you can also access, correct or remove this information. 

Should you have any questions regarding the processing of your personal data, please contact your Privacy Officer or via privacy@bam.com.

If you have a complaint about compliance with this privacy statement, or about a violation of your rights pursuant to the law, please contact the Data Protection Officer.

In addition, you have the option to submit a complaint to the Information Commissioner. For this, use the following link: Make a complaint about how an organisation has used your personal information | ICO.

BAM takes the protection of your data seriously and takes appropriate technical, physical and organisational measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised changes. We do this, for example, by means of the IT security policy, training our employees and by using secure storage and connections.

If you have the impression that your data is not secure or if you have evidence of abuse, please contact our customer service or send an email to privacy@bam.com.