CCTV Privacy Policy

Who we are

Stan Clark Companies

Latest Update March, 2019

This Privacy Policy describes how video surveillance information is collected, used, shared, and stored when you visit any of our locations (including):

  • Eskimo Joe's
  • Eskimo Joe's Clothes
  • Mexico Joe's
  • Stan Clark Companies
  • Eskimo Joe's Promotional Products Group

These companies will collectively be referred to in this policy as "The Companies".


The purpose of this policy is to regulate and outline the safeguards in place regarding the operation, monitoring and access to CCTV systems and resulting images. This policy applies to all employees and all individuals or organizations acting on our behalf.

Closed Circuit Television (CCTV) is used in areas such as:

• Our Offices
• Our Clothing Stores
• Our Restaurants

CCTV systems are installed to:

• Protect and provide for the safety of our guests
• Insure the security of property and other assets
• Deter and detect crime
• Help identify and prosecute offenders
• Provide evidence in prosecutions
• Support law enforcement to deter and detect crime

CCTV systems will not be used for any other purposes than outlined above, for example, CCTV will not be used to monitor the work of employees or monitor attendance.

The Companies' CCTV systems are operated and maintained by:

• The Companies
• Third-party service providers

Each camera will be assigned to the responsibility of a designated and documented member of The Companies staff. This individual will have responsibility for ensuring the proper, efficient and orderly day to day operation of the CCTV system. All data will be stored securely and access to the live feed or recorded images will be restricted to the designated member of staff.

We collect Device Information using the following technologies:

All cameras will operate on a 24-hour day, 7-day week basis. The image quality in most cases allows identification of those individuals in the camera coverage area. The cameras are all fixed and do not allow zoom-in functionality by operators. The Companies not use high-tech or intelligent video surveillance technology, does not inter-connect with other systems, and does not use sound recording or “talking CCTV”. The CCTV system records digital images and is equipped with motion detection. It records any movement detected by the cameras in the area under surveillance, together with time, date and location.

Location and Siting of Cameras
The Companies will, in so far as possible, position cameras in such a way that they only monitor those spaces which are intended to be covered by the system. If it is not possible to restrict coverage, cameras should be positioned to minimize recording of passers-by or private property.

Signs should be placed so that the public are aware that they are entering an area which is covered by a CCTV system. These signs should be clearly visible and legible to members of the public. Such signs should contain the following information:

• the identity of the person or organization responsible for the CCTV installation.
• the purposes of the installation.
• details of who to contact regarding the installation.

Quality of CCTV images
The Companies will ensure, where possible, that images produced by CCTV equipment are effective for the purpose intended. The equipment and recording technology will be maintained on a regular basis to ensure the quality of the images and ensure that no malfunction has occurred.

Retaining Information and Processing Images
Data protection legislation requires that images are not retained for longer than is considered necessary. Unless images are required for law enforcement purposes or legal proceedings, they will not be retained beyond a maximum of 28 days. To protect the security of the CCTV system, a number of technical and organizational measures have been implemented:

• Third-party contractors must enter into an agreement with The Companies that includes non-disclosure and confidentiality clauses
• Third-party contractors and their staff must be properly licensed
• Access rights to users of CCTV footage are granted only where it is strictly necessary


Access to Images
All access to images will be confined to authorized personnel and documented by a designated member of staff.

Access by Data Subjects (Subject Access Request)
Under Data Protection legislation an individual has a right to access information held by The Companies, including CCTV footage and images. All requests should be made, in writing, to The Companies.

Access Requests from Law Enforcement
Law enforcement officers are entitled to view personal data on individuals, if it is for the following purposes:

• for the prevention and detection of crime
• for the prosecution of offenders
• when required urgently to prevent injury or other damage to welfare of the person or serious loss or damage to property
• when required under an order of the Court or any other enactment

New Systems
Before The Companies install or upgrade any new or existing CCTV systems, a documented privacy impact assessment is necessary where deemed appropriate. This will include:

• intended purposes of the CCTV system
• justification
• benefits
• proportionality of installation


We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.


Data Protection Contact Details
For all inquiries relating to Data Protection you can contact The Companies at:


Stan Clark Companies · PO BOX 729 · Stillwater, OK 74076 · USA