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Closed-Circuit Television Privacy Notice for Website under Thailand’s Personal Data Protection Act and the European Union General Data Protection Regulation
17 October 2026
Closed-Circuit Television Privacy Notice
This notice explains how we use closed-circuit television at Chatrium Hotels & Resorts and Maitria Hotels & Resorts properties in Thailand, and the rights you have over images of you. It applies to guests, visitors, contractors and members of the public. It complies with Thailand’s Personal Data Protection Act B.E. 2562 and, where applicable to you, the European Union General Data Protection Regulation.
In short
- What: cameras record video without sound, in public and back-of-house areas of our hotels, resorts and residences.
- Never: there are no cameras in guest rooms, bathrooms, toilets, changing rooms, spa treatment rooms or other private areas.
- Why: the safety and security of guests, employees and property, and the investigation of incidents.
- Legal grounds: we use footage for our legitimate interests under Section 24(5) of Thailand’s Personal Data Protection Act B.E. 2562 and Article 6(1)(f) of the European Union General Data Protection Regulation.
- How long: footage is kept for 30 days, then overwritten automatically, unless it is needed for an incident.
- Who can access it: only designated staff who need the footage to perform their duties. We disclose footage outside the hotel only where required by law or necessary to investigate or manage an incident.
- Your rights: you may ask for a copy of footage of you, and you may object, among other rights. Contact privacy@chatrium.com or the hotel's Front Desk
1. Who is responsible for your data
Each property's operating company is the Data Controller for the CCTV footage recorded there. Chatrium Hospitality manages the properties and coordinates data protection for the group.
| Property | Data Controller (legal entity) | Registered address |
| Chatrium Grand Bangkok | Bangkok Apartment Co., Ltd. | 728 Petchaburi Road, Thanon Phetchaburi, Ratchathewi, Bangkok 10400, Thailand |
| Chatrium Bangkok Riverside (hotel and residence) | Riverside Garden Marina Co., Ltd. | 28 Charoenkrung Road, Wat Prayakrai, Bangkholame, Bangkok 10120, Thailand |
| Chatrium Bangkok Sathon (hotel and residence) | Chatrium Residence Sathon Co., Ltd. | 291 Naradhiwas Rajanagarindra Rd. Soi 24, Chongnonsee, Yannawa, Bangkok 10120, Thailand |
| Chatrium Phuket Rawai | Baron World Trade Co., Ltd. | 49 Soi Pipat (Silom 3), Silom Road, Silom, Bangrak, Bangkok 10500, Thailand |
| Chatrium Golf Chanthaburi Soi Dao | Chanthaburi Country Club Co., Ltd. | 49 Asia Sermkij Tower, Soi Pipat, Silom Road, Bangrak, Bangkok 10500, Thailand |
| Emporium Suites by Chatrium | Sukhumvit City Co., Ltd. | 622 Sukhumvit Road, Klongton, Klongtoey, Bangkok 10110, Thailand |
| Lacol Khaoyai - A Chatrium Collection | KorkiertKhaoyai Co., Ltd. | 369 Moo 4, Thana Rat Road, Tambon Mu Si, Amphoe Pak Chong, Nakhon Ratchasima 30130, Thailand |
| Maitria Sukhumvit 18 Bangkok | Sukhumvit City Co., Ltd. | 26 Sukhumvit Soi 18, Sukhumvit Road, Klongtoey, Bangkok 10110, Thailand |
| Maitria Rama 9 Bangkok | City Villa Co., Ltd. | 928 RimklongSamsen Road, Bangkapi, Huay Kwang, Bangkok 10310, Thailand |
| Maitria Residence Rama 9 Bangkok | City Villa Co., Ltd. | 928 RimklongSamsen Road, Bangkapi, Huay Kwang, Bangkok 10310, Thailand Contact for all properties |
Data Protection Officer, Chatrium Hospitality 28 Charoenkrung Soi 70, Bangkholame, Bangkok 10120, Thailand Email: privacy@chatrium.com Telephone: +662 3078888
You may also speak with the Front Desk at any of our properties, who will pass your request to the Data Protection Officer the same day.
Privacy safeguards and continuous impact assessment
To ensure that our technology and operations do not compromise your fundamental rights, we apply privacy by design principles strictly. In line with Article 35 of the European Union General Data Protection Regulation and Thailand’s Personal Data Protection Act B.E. 2562, our appointed Data Protection Officer independently conducts a formal data protection impact assessment before any high-risk processing activity begins, including the use of our property-wide security camera network.
Our Data Protection Officer reviews the data protection impact assessment regularly, at least every 3 years, and immediately following structural changes to the camera network, the introduction of new analytical technologies, or a security audit.
2. Where we use cameras
Cameras cover areas where security risks are foreseeable. CCTV notices are displayed in the hotel lobby and at the employee entrance of each property, and apply to all monitored areas of that property.
- Covered: entrances and exits of each building within the premises, lobbies, lift landings and corridors, car parks and driveways, restaurant, bar and function entrances, pool and beach access points, the building perimeter, and back-of-house areas such as loading bays, cash offices and stores.
- Never covered: guest rooms and suites, residence apartments, bathrooms and toilets, changing rooms, spa and treatment rooms, staff rest areas, or any other place where you can reasonably expect privacy.
- Not used: We do not record sound. We do not use facial recognition or other biometric identification. Cameras are not used to monitor guests' behaviour for marketing.
Camera positions are reviewed at least every quarter, so that each camera covers only what its purpose needs.
3. Why we use closed-circuit television and the applicable legal grounds
We rely on legitimate interests for CCTV, not on consent. A hotel cannot ask everyone who walks past a camera for consent, and you should not have to give it to stay safely.
| Purpose | Thai law | European Union law |
| Protect the safety of guests, visitors and employees | Legitimate interest, Section 24(5); vital interest, Section 24(2), in emergencies | Article 6(1)(f); Article 6(1)(d) in emergencies |
| Prevent, detect and investigate crime, theft and damage to property | Legitimate interest, Section 24(5) | Article 6(1)(f) |
| Investigate incidents, accidents and complaints, and establish, exercise or defend legal claims | Legitimate interest, Section 24(5) | Article 6(1)(f) |
| Respond to lawful requests from the police, courts or regulators | Legal obligation, Section 24(6) | Article 6(1)(c) where European Union or Member State law applies; otherwise Article 6(1)(f) |
When we rely on legitimate interests to use closed-circuit television, we assess 3 test: the purpose, the necessity, and the balance between our interests and individuals’ rights and freedoms. We record the outcome in our legitimate interests assessment for the use of closed-circuit television.
Purpose test. We use CCTV to protect the safety and security of guests, employees and visitors, prevent and investigate theft, unauthorisedaccess and property damage, and preserve evidence of security incidents. These interests are supported by the need to maintain a safe hotel environment and protect people and property.
Necessity test. CCTV is used in appropriate areas, such as entrances, reception, corridors, car parks and other relevant common areas, where necessary to achieve these purposes. Less intrusive measures, including access controls, lighting and security patrols, may not provide equivalent evidence or incident coverage. Camera views, access to footage and retention periods are limited to what is reasonably necessary.
Balancing test. We consider the privacy and rights of guests, employees and visitors when determining camera locations and use. CCTV is not installed in private areas such as guest rooms, bathrooms or changing rooms. Access to footage is restricted to authorised personnel, and footage is retained only for the applicable retention period, or longer where lawfully required for an incident or legal claim.
We weigh our legitimate interests against the rights and freedoms of individuals and apply appropriate safeguards to minimise privacy impacts. Where legitimate interests do not provide an appropriate lawful basis, we will identify another valid legal basis before processing.
This assessment is reviewed periodically and whenever the purposes, risks or circumstances of CCTV processing materially change.
No new purposes. We do not use footage for any purpose not listed here. If we ever need to, we will update this notice first and, where the law requires, ask for your consent.
4. What we record, how long we keep it and who sees it
What we record. Moving and still images of people and vehicles in covered areas, with the date, time and camera location. No sound is recorded.
How long we keep it. Footage is overwritten automatically after 30 days. If footage is needed for an incident, claim, complaint or official request, the relevant clips are kept for up to 90 days. They are kept beyond that only while the matter remains open, then deleted.
Who can see it. Only named security staff, the Hotel Manager, the General Manager and the Data Protection Officer can view footage, and every viewing or export is logged. Live monitoring takes place in a secured control room.
When we share it. We disclose footage only:
- to the Royal Thai Police, courts, emergency services or regulators, when the law requires it or on written request;
- to our insurers, loss adjusters or legal advisers, when a claim or incident requires it;
- to you, when you exercise your right of access (Section 5).
Every disclosure needs written approval from the General Manager or the Data Protection Officer. Footage is never sold, used for advertising, or posted on social media.
Where it is stored. Footage is stored on secured recording equipment at each property in Thailand and is not transferred outside Thailand. If that changes, we will update this notice and apply the safeguards required by Sections 28 and 29 of Thailand’s Personal Data Protection Act B.E. 2562 and, where the European Union General Data Protection Regulation applies, Chapter V of that regulation.
Security. Recording systems sit on a restricted network with controlled credentials. Exports are encrypted, and the evidence chain of custody is recorded for any clip we preserve.
5. Your rights
You have the following rights over footage of you. Because footage is overwritten after 30 days, please contact us as soon as possible; we preserve the relevant clips as soon as your request arrives.
| Right | Thai law | European Union law |
| Access and obtain a copy of footage of you | Section 30 | Article 15 |
| Object to our use of footage based on legitimate interests | Section 32 | Article 21 |
| Ask us to delete footage | Section 33 | Article 17 |
| Ask us to restrict use of footage (for example, to keep it while you bring a claim) | Section 34 | Article 18 |
| Ask us to correct inaccurate data linked to footage | Sections 35 and 36 | Article 16 |
| Complain to a supervisory authority | Section 73 | Article 77 How to make a request. Write to privacy@chatrium.com, post a letter to the Data Protection Officer at the address in Section 1, or hand a written request to the Front Desk. To find the right footage, please give: |
- the property, date and approximate time (within a one-hour window);
- where you were (for example, lobby or car park);
- a description or recent photograph so we can recognise you.
We will verify your identity before releasing any footage.
Our response times. Under Thailand’s Personal Data Protection Act B.E. 2562, we check your request within 15 days and answer within 30 days. Complex requests may take up to 30 additional days, and we will explain why. Where the European Union General Data Protection Regulation applies, we answer within one month, extendable by two months where the law allows. Requests are free of charge unless they are manifestly unfounded or excessive, in which case we may charge a fee within legal limits or decline the request.
Other people in the footage. To protect other people's privacy, we blur or mask anyone else who can be identified. Where that is not possible, we may provide still images or a written description instead.
When we may decline. We may refuse or limit a request where the law allows it. Examples include a court order, an active police investigation, or where disclosure would harm other people's rights. If we do, we will explain why in writing and tell you how to complain.
Objection. If you object, we will stop using footage of you unless we have compelling legitimate grounds that override your interests, or we need it to establish, exercise or defend a legal claim.
Complaints. We would like the chance to resolve any concern first. You may also complain to:
• Thailand: the Office of the Personal Data Protection Committee, www.pdpc.or.th
• European Union: the data protection authority in the EU member state where you live or work, or where the issue arose.
6. Changes to this notice
We review this notice at least once a year and whenever our use of CCTV changes. The current version is always published here, and printed copies are available at the Front Desk and the employee entrance of every property. This notice is published in English and Thai; if the two differ, the Thai version prevails for properties in Thailand.
Version 1.0. Effective 19 October 2026. Applies to Chatrium Hotels & Resorts and Maitria Hotels & Resorts properties in Thailand. Properties in Japan, Myanmar and China have their own local notices.