Birmingham 2022 Commonwealth Games (“The Games”) Supplementary Privacy Notice – Recording of Images, Footage and Sound Recordings at the Queen’s Baton Relay


About us

We are the Birmingham Organising Committee for the 2022 Commonwealth Games Limited (“Birmingham 2022”, “we”, “us”, or “our”.  Below is set out the out relevant information about what we will do with the personal data which we collect as a result of your involvement with or attendance at the 2022 Commonwealth Games Queen’s Baton Relay.  For further information please see our website privacy notice at


Who does this supplementary privacy notice apply to?

This supplementary privacy notice applies to all those involved with or who attend the Queen’s Baton Relay, including: children (and their parents and guardians), athletes, volunteers, batonbearers, B2022 staff, the Commonwealth Games Association (“CGA”) contacts/ members, local authority contacts and various members of the general public.


The Queen’s Baton is recording – What information do we collect and why do we need it?

For the first time ever, the Queen’s Baton contains a camera which will be capturing 360 degree images, footage and sound recordings as it makes its way across the Commonwealth. This means that if you are involved in the Queen’s Baton Relay in any way, or if you come along to see the Baton on its exciting journey and you’re recorded by its camera, we will be collecting your personal data and will be data controller of that information.

We’re recording these images, footage and sounds for promotional activities relating to the 2022 Commonwealth Games and will be storing it for archiving purposes in relation to these Games and for future games to come.

We also want to let you know of another way we might collect your personal data. While you’re attending or participating in the Queen’s Baton Relay, you might also appear in images, footage or sound recordings taken by one of the official photographers or videographers used by your local CGA and they, as data controller of your personal data, may share these images with us. When they do so, there may be occasions where both we and your local CGA may both be considered to be joint controllers of your personal data, but our responsibilities to you in relation to your data protection rights remain the same.

As set out above, we will only be using these images, footage and sound recordings for the purpose of promoting the 2022 Commonwealth Games and so that we can archive the images of the event.


Who will have access to your personal information?

If you appear any of the images, footage or sound recordings taken by the Baton, we may share your personal information with the following entities:

  • CGAs;
  • News organisations;
  • Broadcasters; and
  • On the official Birmingham 2022 pages of social media platforms such as Tik Tok, Facebook, Twitter and Instagram.

If, for any reason, we have to transfer your personal data outside of the UK or EU, we will only do so where there are secure transfer mechanisms in place, as approved by the Information Commissioner’s Office.


How is processing your information lawful? Our lawful basis for processing your information is that it is in our legitimate interest to do so for the purposes of promotion of the 2022 Commonwealth Games, the Queen’s Baton Relay itself and to archive this information for the future.


If some of the images, footage or sound data we collect contains any personal data which is considered to be special category data, we consider this data to be information made manifestly public by you, the data subject, by your involvement with or attendance at the Queen’s Baton Relay.


How we protect your personal data

Please see our website privacy notice at


How long do we keep your personal data?

Images, footage and sound recordings will be retained for the purpose of promoting future Commonwealth Games and related events.


Your data protection rights

Please see our website privacy notice at


How to contact us

Please see our website privacy notice at


Changes to this privacy notice

We regularly review and, where necessary, update our privacy information. If we plan to use personal information for a new purpose, we update our privacy information and will communicate the changes via an update to this supplementary privacy notice and/or to our website privacy notice. Please check our website occasionally to ensure you are aware of the most recent version of our website privacy notice. This supplementary privacy notice is version 1 and is effective from October 2021.