Video surveillance
EXTENDED SECOND-LEVEL INFORMATION ON VIDEO SURVEILLANCE EDPB GUIDELINES 3/2019 WALCOR SRL - ROME
• Art. 13 EU Regulation 679/2016 of the European Parliament and of the Council ("GDPR"); • Legislative Decree 196/2003 and subsequent amendments and additions;
• Art. 3.1 Provision of the Guarantor regarding video surveillance - 8 April 2010; • Law no. 300 of 1970 (so-called Workers' Statute), art. 4, paragraph 1;
• Additional rules identified by the Controller regarding video surveillance;
1. Subject
This information, which supplements the content of the simplified information, is provided pursuant to and for the purposes of art. 13 of the GDPR, and art. 3.1 of the Provision of the Guarantor regarding video surveillance - 8 April 2010 (Video Surveillance Provision) in order to inform that video surveillance systems are in operation at the registered office at Via di Tor Sapienza 34, in compliance with the aforementioned provisions and your rights.
2. Simplified information pursuant to art. 3.1 of the Video Surveillance Provision
The video-monitored areas are marked with appropriate signs, in accordance with art. 3.1 of the Video Surveillance Provision, clearly visible in all lighting conditions, where the purposes pursued are also indicated. These signs are placed before the cameras' range of action or in their immediate vicinity.
3. Data Controller
The Data Controller is Walcor S.r.l., in the person of its legal representative pro tempore, who can be contacted at the following addresses: Tel. 062284544; email address amministrazione@walcor.it. Walcor S.r.l. has appointed a Data Protection Officer (DPO), Dr. Paolo Franco, who can be contacted at the address, – telephone number 347-3999696.
4. Data Processor
The Controller has appointed Mr. Corrado Bucceroni, pro-tempore director of the Board of Directors, as the Data Processor.
5. Purpose of processing
Video surveillance systems have been installed for the following purposes:
a) Security against unlawful interference;
b) Protection of company assets and prevention of acts of vandalism or damage;
c) Logistic and/or operational needs and any other purpose required by specific legal or regulatory provisions.
6. Legal basis for processing
The video surveillance activity carried out by Walcor S.r.l. is lawful as it is based on pursuing its legitimate interest (art. 6, par. 1 lett f) GDPR), which must include the purposes indicated in point 5 of this information notice.
7. Recipients or categories of recipients of personal data
The recipients (i.e., the natural or legal person, public authority, service, or other body that receives communication of personal data) of personal data acquired through the video surveillance systems of all sales points are:
• Employees and supervisors, expressly designated and authorized, both to access the premises where the control stations are located and to use the systems and, where indispensable for the purposes pursued, to view the images, to whom specific instructions have been provided. Authorized personnel have differentiated access levels, depending on their specific tasks. The processed data will not be disseminated and will not be communicated to third parties, except to judicial authorities and judicial police.
8. Types of personal data processed
The video surveillance systems record audiovisual material on specific storage media and may concern both common personal data and other categories of personal data as per Articles 9 and 10 of the GDPR.
9. Transfer of data to a third country
Your data will not be transferred outside the European Union.
10. Image retention period
Recorded images are stored and accessible by authorized personnel, in full compliance with the provisions of the Video Surveillance Provision, for a period not exceeding 72 hours. They are retained for an additional 30 days, solely for access by law enforcement agencies, and subject to special needs for further retention in relation to judicial police investigations or requests from the judicial authority, or for further periods necessary to satisfy the purposes for which the images are collected, in compliance with the obligations imposed by security regulations. The systems are programmed to automatically delete all information at the pre-set time upon expiry of the specified term for each medium, including through overwriting, in such a way as to render the deleted data unusable. Information stored on media that does not allow reuse or overwriting is destroyed within the maximum period provided for the specific video surveillance purpose pursued.
11. Data subject's rights
Data subjects may exercise at any time the rights established by Articles 15-22 of the GDPR. Below are the rights you can exercise with regard to video surveillance:
1. You have the right to request from the Controller access to your personal data and information relating thereto, the rectification of inaccurate data or the integration of incomplete data, the erasure of personal data concerning you (if one of the conditions indicated in Article 17, paragraph 1 of the GDPR applies and subject to the exceptions provided for in paragraph 3 of the same article, for example, if your data is processed unlawfully), the restriction of processing of your personal data (if one of the hypotheses indicated in Article 18, paragraph 1 of the GDPR applies, for example, your data is processed unlawfully).
• You have the right to object at any time to the processing of your personal data in the event of particular situations concerning you.
• You have the right to lodge a complaint with a supervisory authority (Italian Data Protection Authority – www.garanteprivacy.it), and to appeal to the ordinary judicial authority.
The aforementioned rights can be exercised within the limits indicated in art. 3.5 of the Video Surveillance Provision. In particular, with reference to recorded images, the right to update, rectify, or integrate cannot be exercised in practice given the intrinsic nature of the collected data, as these are images collected in real time concerning an objective fact.
The rights can be exercised by contacting the Data Controller and using the appropriate forms available on the website of……………………..., by sending the request to………………………………. -…………………………………. Rome via email………………………………….
12. Automated decision-making, including profiling
Your personal data will not be subject to any automated decision-making process, including profiling.
13. Update
This information may be supplemented with further indications, also considering regulatory changes or measures from the Privacy Guarantor.
Request for the exercise of rights implying intervention on data (rectification/erasure/restriction)
The undersigned _______________________ born in ____________ on ___/___/____ and residing in _________________ at Via/Piazza_______________________ no.________ kindly requests, in accordance with the regulation in question, to perform the following operations:
rectification of data to the extent that ;__________________________________________________________________________________________________________________________________________________________________________________________________
erasure of data because (mark the applicable option):
personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
withdrawal of consent on which the processing is based (and absence of another legal basis for the processing);
objection to processing for______________________________________________________________________________________________________________________________ ; personal data have been unlawfully processed;
personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
personal data have been collected in relation to the offer of information society services to a child where the child is over 16, or from a parent or guardian if the child is younger, the restriction of processing of personal data because_____________________________________________________________________________________________________________________________________________________________________________________________ (including those for which retention is not necessary);
attestation that the requested intervention on the data has been brought to the attention, also as regards its content, of those to whom the data have been communicated or disseminated.
This request concerns (please indicate the personal data, categories of data, or processing to which it refers):
___________________________________________________________________________________________________________________________________________________________________________________________________
Identification document details:
_________________________________________________________________
Awaiting a kind reply, I send my best regards.
Place………, date ……………………. SIGNATURE
Form for exercising the right of access (ex. Art. 15. GDPR)
The undersigned _______________________________ born in _________________ on ___/___/____ and residing in _______________ at Via/Piazza_________________________ no._____ kindly requests, in accordance with the aforementioned legislation, to have confirmation of the existence, at your Company, of personal data concerning them in relation to the processing regarding_____________________________________________________ and to receive communication thereof (check requests):
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
the existence of appropriate safeguards pursuant to Article 46 of the GDPR relating to the transfer of data outside to non-EU countries.
Identification document details:
___________________________________________________________
Awaiting a kind reply, I send my best regards.
Place………, date ……………………. SIGNATURE
Form for exercising the right not to be subject to automated decision-making (ex. Art. 22 GDPR)
The undersigned ___________________________________ born in ____________________ on _______/______/_________ and residing in ______________________ at Via/Piazza_______________________ no._______ kindly requests, in accordance with the regulation in question, to perform the following operations:
the exclusion of processing that involves being subjected to automated decisions affecting one's freedom to________________________________________________________________________________________________________________________________________________________________________________________________ .
This request concerns (please indicate the personal data, categories of data, or processing to which it refers):
___________________________________________________________________________________________________________________________________________________________________________________________________
Identification document details:
_________________________________________________________________
Awaiting a kind reply, I send my best regards.
Place………, date ……………………. SIGNATURE
Form for exercising the right to data portability (ex. 20 GDPR)
The undersigned ___________________________________________ born in ____________________________ on ___/___/____ and residing in __________________ at Via/Piazza______________________________ no._______ kindly requests, in accordance with the regulation in question, to perform the following operations:
Receiving their personal data in a structured, commonly used, and machine-readable format. Direct transmission of their data to __________________________________________________________________________________________________________________________________
This request concerns (please indicate the personal data, categories of data, or processing to which it refers):
__________________________________________________________________________________________________________________________________
Identification document details:
_________________________________________________________________
Awaiting a kind reply, I send my best regards.
Place………, date ……………………. SIGNATURE
Form for exercising the right to object to processing (ex. Art. 21 GDPR)
The undersigned ______________________________________________ born in ___________________________________ on _____/_____/______ and residing in _________________ at Via/Piazza_________________________________ no._____ , pursuant to the aforementioned legislation, objects to the processing of data carried out for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication. objects to the processing of data for the following legitimate reasons:
___________________________________________________________________________________________________________________________________________________________________________________________________
This request concerns (please indicate the personal data, categories of data, or processing to which it refers):
___________________________________________________________________________________________________________________________________________________________________________________________________
Identification document details:
_________________________________________________________________
Awaiting a kind reply, I send my best regards.
Place………, date ……………………. SIGNATURE