PERSONAL DATA PROCESSING BY VIDEO SURVEILLANCE SYSTEM
POLICY AND INFORMATION FOR DATA SUBJECTS
This document describes our structure’s policy regarding video surveillance in terms of the management and protection of personal data. It contains all transparent, compulsory information required pursuant to art. 13 of EU Regulation 2016/679, (hereafter GDPR) and art. 4, Italian Law No. 300/1970 (hereafter Workers’ Statute).
The data controller for personal data collected by a video surveillance system is Armony S.p.A. (hereafter Company) single shareholder company, registered office Via Pradego 32, Caneva (PN) 33070, which can be contacted at the email address: email@example.com.
Description and Scope of the Video Surveillance System
Our video surveillance system meets the need for opportune security of the company’s activities and assets, its employees, associates and visitors, and for the safety of those who work and/or are on our premises. The filming and recording system is designed to prevent illicit and wilful misconduct (thefts, damage, vandalism and other illicit acts to persons or assets), and serves the purposes of investigating injurious or damaging acts or facts.
The cameras are located at perimeter access points and in several areas of the buildings and their appurtenances. In certain places and areas work or correlated activities are carried out, or could be carried out, that may be filmed by the videocamera (live and/or recorded images, according to the cases described in this policy), in any case strictly for the purposes and using the methods described in this document.
Aims and Legal Basis for Processing Personal Data
- To protect the company’s assets, employees and third persons on the premises;
- To fulfil the purpose of increasing the safety of the people on the premises against aggression or threats;
- To facilitate criminal investigation or judicial inquiries by authorised public officials (police forces and investigating magistrates);
- To prevent acts against public safety and/or to deter criminals or actions that have the potential to interrupt public services, etc.
The legal basis, i.e. what renders processing without the subject’s consent legal, is the company’s need to perform processing to pursue its legitimate interests for the above-mentioned aims.
Principles Applicable to Processing and Relative Processing Methods
All processing of personal data will take place observing the principles indicated in art. 5 of the GDPR (lawfulness, accuracy, transparency, suitability, pertinence, needs and proportionality), and will also conform to art. 4, clause III, of the Workers’ Statute.
The video cameras and recording system are able to identify the people filmed in all conditions (in daylight and at night) and are used to protect the physical safety of those on the premises: employees, associates and visitors; they are used to preserve the orderly, safe performance of the activities carried out on the perimeter and to protect the data controller’s property and the assets therein, whether they belong to the company or to other subjects, including visitors.
The system will operate 24/7 and the images will be recorded.
Recordings are made on a server and computers and are managed digitally.
Images will be stored for no longer than is necessary to fulfil the aims described above and in any case no more than 24 hours, except in special, justifiable cases of a need to store for longer, and when it is necessary to meet the special requirements of legitimate subjects.
Once the storage period has expired, the system automatically deletes the images.
Provision of Data and Consequences of Failure to Provide Them Provision of data is intrinsic to accessing the video surveillance areas and is therefore necessary. Whoever is about to come within the video camera’s cone of vision is warned by special signage that he or she is entering a video surveilled area. Therefore, if a person does not want to be filmed, he or she must not enter the area.
Categories that may Receive Data
Personal data will be processed by internal staff authorised by Armony S.p.A. according to their respective duties and profiles, as well as by external providers of surveillance services who are appointed by the company as data processors.
Rights of Data Subjects
Data subjects (those who are filmed and recorded) enjoy the rights acknowledged by the GDPR (arts. 15 to 22) and therefore have the right, if foreseen, to require access to their personal data, have them erased or their processing restricted.
To exercise their rights and for all other issues pertaining to the processing of personal data, data subjects may write to the company at the email address firstname.lastname@example.org.
Data subjects also have the right to lodge a complaint with the supervisory authority (Garante) regarding protection of their personal data: www.garanteprivacy.it.
Transfers of Data to Third Countries or International Organisations Video-recorded material will not be transferred to third countries (non-EU nations) or to international organisations.
Labour and Employment Law
Authorisation of our video surveillance system was issued by the Territorial Labour Inspectorate of Udine-Pordenone on 10/02/2021, pursuant to art. 4, clause I of Italian Law No. 300/1970, amended by art. 23 of Italian Legislative Decree No. 151/2015.
The purpose of Armony S.p.A. in issuing this company policy is to fulfil its obligation towards all data subjects and those in general who frequent its structure, as well as its obligation to inform employees, as per art. 4, clause III of the Workers’ Statute, with regard to the way in which video surveillance is used and access is gained to the images.
Revision and Amendments to the System and Policy
Any updating of the video surveillance system will require a revision of this document and compliance with any further disposals of the Workers’ Statute and the regulations regarding the protection of personal data. In particular, further administrative authorisation may be required from the competent Territorial Labour Inspectorate, and employees will be suitably and promptly informed, also by posting the information on the notice board.