Video Surveillance Policy
1. Data controller
EUROPEAN RELIANCE GENERAL INSURANCE CO.S.A., 274 Kifisias Avenue, 15232, Chalandri, tel.: +30 210-6829601, email: firstname.lastname@example.org.
2. Contact details of the Data Protection Officer
For any matter related to personal data processing via the video surveillance system, you may contact the Data Protection Officer (DPO) of the Company at +30 210-8119670 or the email: email@example.com.
3. Purpose of data processing and legal basis
We use the video surveillance system, to protect people and goods. The processing is necessary for the purposes of legal interests that we strive for as data controller (article 6, par. 1, per. f. of the GDPR).
4. Analysis of the legal interests
Our legal interest is based on the need to protect our spaces and goods from unlawful acts, such as thefts. The same applies for the safety of life, physical integrity, health and property of our personnel and third parties that legally work in the spaces under surveillance. We collect only imaging data and limit the surveillance mostly in the spaces that we have evaluated that present an increased possibility for unlawful acts, i.e. theft or unauthorized access around the entrances of the central buildings, parking stations and warehouses, without focusing video surveillance on spaces that could have as a result the limitation of the private life of the persons in the images, and taking into consideration their right for respect of the personal data.
The stored material is accessible only to our competent / authorized personnel that is entrusted with the safety of the space or the investigation of possible cases and offenses. This material cannot be transferred to third parties, with the exception of the following cases: a) the competent judicial, prosecution and police authorities that include data necessary for the investigation of an offense, which refers to people or goods of the data controller, b) to the competent judicial, prosecution and police authorities that legally request data, at the performance of their duties, and c) the victim or the perpetrator of an offense, when the data are evidence of the offense.
6. Retention period
As a company that belongs in the category of financial institutions, we preserve the data for forty-five (45) days, and after this time period, the data will be erased. If, in this time period, we discover an incident, we isolate a part of the video and keep it for one (1) month, for the investigation of the incident and the beginning of legal procedures for the defense of our legal interests, whereas, if the incident refers to a third party, we will keep the video up to three (3) months.
7. Rights of the data subjects
The data subjects have the following rights:
• Right of access: You retain the right to know whether we process your image, and if this applies, to have a copy of it, under the prerequisite that the rights of other natural persons are not affected.
• Right to restrict processing: You retain the right to ask us to limit our processing, i.e. to not erase data that you consider necessary for the establishment, performance or support of legal claims.
• Right to object: You retain the right to object to the processing.
• Right to erasure: You retain the right to request for erasure of your data, provided these are not considered necessary for the establishment, performance or support of the legal claims.
It is highlighted that in the typical video surveillance systems, the above rights are implemented, whereas in exceptional cases, additional rights that are included in the GDPR can be implemented.
You may exercise your rights by sending an email at firstname.lastname@example.org or via our postal address. In order to examine a request related to your image, you will need to define with the best possible accuracy, the time that you were in the scope of the security cameras (date, time, place, etc.) and give us your picture, to facilitate the identification of your data and conceal the data of depicted third parties. Alternatively, we will give you the opportunity to visit our facilities and present to you the images in which you appear, provided these have been stored. The exercise of your right to object or the right to erasure does not imply immediate erasure of the data or modification of the processing. In any case, we will reply to you as soon as possible, within the deadlines defined in the GDPR.
8. Right to lodge a complaint
In case you consider that data processing violates the EU Regulation 2016/679, you have the right to lodge a complaint in the supervisory authority.
The competent supervisory authority for Greece is the Hellenic Data Protection Authority, 1-3 Kifisias Avenue, 11523, Athens, https://www.dpa.gr/, tel. +30 2106475600.