Notice on CCTV Personal Data Processing
INTRASOFT International S.A., 2b rue Nicolas Bové, L-1253, Luxembourg, email: firstname.lastname@example.org, website: https://www.intrasoft-intl.com
Purpose of processing and legal basis
We use a CCTV system to protect persons and goods. Processing is necessary for the purposes of the legitimate interests which we as a data controller pursue (Article 6( 1)(f) GDPR).
Analysis of legitimate interests
Our legitimate interest is the need to protect our premises and the goods located there from illegal acts, such as theft. The same also applies to the safety of life, physical integrity, health and the property of our staff and third parties who are lawfully present in the area under surveillance. We only collect image data and limit the recording of images to locations where we have determined that there is an increased likelihood of unlawful acts being committed, such as entrances and exits, without focusing in on areas where the privacy of persons whose image is obtained, including their right to respect for personal data, may be excessively restricted.
The materials held can only be accessed by our competent / authorised staff who are charged with site security. This material is not sent to third parties without the consent of the data subject, with the exception of the following cases: date sent: a) to the competent judicial, prosecuting and police authorities when it includes information necessary to investigate a criminal act which relates to persons or the data controller’s goods, b) to the competent judicial, prosecuting and police authorities when they request data lawfully when discharging their duties, and c) to the victim or perpetrator of a criminal act in the case of data which could constitute evidence of the crime.
We keep the data for 15 days after which it is automatically deleted. If an incident is identified during that period, we isolate that section of the video and keep it for up to 1 month to investigate the incident and to commence legal proceedings to safeguard our legitimate interests, and if the incident relates to a third party, we will keep the video for up to 3 months.
The rights of data subjects
Data subjects have the following rights:
- Right of access: You are entitled to learn whether we are processing your image and, if so, to receive a copy of it.
- Right to restrict processing: You are entitled to request that processing be limited, such as not deleting data you consider necessary to establish, exercise or support legal claims.
- Right to object: You are entitled to object to processing.
- Right of erasure: You are entitled to request that we delete your data.
You can exercise your rights by sending an email to the address email@example.com or by submitting a request in person to the address where the CCTV system relevant to you is installed. To enable us to examine a request relating to your image, you need to specify when you were in the vicinity of the cameras and provide us with an image of you to make it easier for us to identify your own data and to conceal the data of third parties who were involved. Alternatively, we will allow you to visit our facilities to show you the images you appear in. We would also point out that exercising your right to object or delete data does not entail the immediate deletion of data or modification of how it is processed. In all events, we will respond in detail as soon as possible within the deadlines laid down by the GDPR.
Right to submit a complaint
If you consider that the processing of data relating to you is contrary to Regulation (EU) 2016/679, you are entitled to submit a complaint to the supervisory authority.
The competent supervisory authority for Greece is the Hellenic Data Protection Authority, 1-3 Kifissias Ave., Athens GR-11523, https://www.dpa.gr/, Tel. 2106475600.
Last update: 3/8/2020