FAQS

We are trialling the use of Live Facial Recognition Technology (LFRT) at our Palm Beach Casino, 30 Berkeley St, Mayfair, London W1J 8EH for a period of 3 months from 9th October 2023. At the end of the trial period, we will review the trial outcomes and may decide to continue our use of LFRT on a longer-term basis or extend its use to our other UK casinos. Where that is the case, we will make further updates to the Genting Privacy Notice and these FAQs.

Genting Casinos UK Limited acts as independent Data Controller of personal data collected and processed through our use of LFRT at the Palm Beach Casino, including for all biometric data. We are registered with the Information Commissioner’s Office.

LFRT involves comparing a person’s unique facial features against a database to identify ‘persons of interest’. If you enter the Palm Beach Casino during the trial period, LFRT cameras located at reception will scan your face to produce a unique biometric template. This is then compared against biometric templates held on the database. If there is a match to a ‘person of interest’, the system will alert our staff to your presence in the casino. A manager will then hold an interaction with you, and you may be asked to leave the premises depending on the circumstances.

The trial will only use LFRT to identify the following categories of persons of interest, each of whom will have an entry on the database:

• A sample group of people who are already suspended / barred from Genting Casinos for responsible gambling reasons. • People who are already suspended / barred from Genting Casinos further to the prevention or detection of crime, unlawful acts and disorder.

The trial will not make use of LFRT for any other purpose, nor will it be used to identify people outside of these groups.

Updated November 2023: The ‘persons of interest database’ is created by Genting using data from our existing casino management and security records only. We use photographs of individuals within our existing records who are currently recorded as suspended / barred from Genting premises for responsible gambling reasons or further to the prevention or detection of crime, unlawful acts or disorder. We do not use data from other sources (including from the self-enrolment national self-exclusion database directly (SENSE)) or from other third parties, such as commercially or publicly available databases or social media websites. For data minimisation purposes, the trial will make use of a limited data set from our casino management records as a proof of concept.

Clarification re. SENSE: following recent feedback, we are updating this section of the FAQs to clarify that the trial data used to identify persons suspended / barred for responsible gambling reasons (including where previously referred to as “SENSE” registered individuals) originates from Genting’s own casino management and security records and not from the SENSE self-exclusion database as a third-party scheme. We have therefore removed references to “SENSE” to clarify that SENSE is not affiliated with the Palm Beach trial, it does not share data with Genting Casinos as part of the trial, nor will it act as a data controller or processor at any stage of the trial.

If the trial is successful, we may explore working with SENSE more formally to help identify and safeguard all individuals with a live SENSE self-exclusion agreement in place, but this is subject to further review and industry engagement. Both Genting and SENSE will update their privacy information if they agree to work together in this way in the future. If you have questions regarding this section, please contact our Data Protection Officer on DPO@gentinguk.com who will be happy to clarify.

Genting has identified the following lawful bases under the UK data protection laws (including the UK GDPR and Data Protection Act 2018) to support its trial of LFRT for the purposes described above:

• further to our legal obligations under the UK Gambling Commission’s Licensing Conditions and Codes of Practice (LCCP) to protect vulnerable persons from being harmed by gambling and to prevent gambling from being associated with crime and disorder ; • further to our legitimate interests; and • in the substantial public interests of safeguarding individuals at risk and preventing or detecting unlawful acts – this also applies to the processing of special category biometric data created in the use of LFRT.

Genting has also carried out a detailed Data Protection Impact Assessment (DPIA) to support its use of LFRT and has reviewed the prevailing guidance on LFRT from the ICO and the Biometrics and Surveillance Camera Commissioner.

The following types of data are collected or created as part of the end-to-end LFRT process:

• Live-stream recording on entry to the Palm Beach Casino – this operates in a similar way to traditional CCTV. • Facial extract from live-stream recording – these are images of a person’s face cropped from the live stream. • Unique biometric template created from facial extract – this is generated by the LFRT software and takes the form of a binary, numerical value that cannot be used by anyone else to identify you. The biometric template is sent to the database and compared against customer photographs already held in our casino management and security records for existing ID verification purposes. • Positive result alerts and associated data – positive alerts are recorded in writing and retained as part of the customer record. Details of any interaction carried out by our staff and subsequent action is also recorded.

In most cases, you will already know if you meet the criteria of a person of interest, i.e. you will know if you are currently **suspended / barred from Genting Casinos for responsible gambling reasons or for the prevention or detection of crime, unlawful acts or disorder.

If you know yourself to be a ‘person of interest’ based on the above criteria, we advise you not to enter the casino. Prominent signage is also on display at the Palm Beach Casino to notify individuals that LFRT is in use before they enter the premises.