Guidelines on processing of personal data through Video Surveillance System
1. Data Controller:
A. PETROPOULOS & ASSOCIATES LAW FIRM, as duly represented by Mrs. Nadia Petropoulou, 48, Zaimi Str., Athens, 106 83, contact no. +30 210 82 22 717.
2. Purpose and lawfulness of processing
We use a surveillance system for the purpose of protecting individuals and goods. The processing is necessary for the purposes of legitimate interests pursued by our law firm, as Data Controller (article 6, par. 1 f, GDPR).
3. Analysis of legitimate interests
Our legitimate interest serves our need to protect our premises and the goods thereto from illegal acts, such as theft. The same applies to the safety of life, physical integrity, protection of health and property of our personnel and third parties who are lawfully present in the supervised area. We only collect image data and limit image capture to areas we consider that there is an increased likelihood of illegal acts to take place e.g. theft, such as at the entrance
of our premises, without focusing on areas where the privacy of the individuals, whose image is captured may be severally limited, including their right to have their personal data respected.
The stored material is only accessible by our competent/authorized personnel who are responsible in charge for the security of our premises. Such material is not transferred to third parties, with the exception of the following cases: (a) to the competent judicial, prosecutorial and police authorities, when such material includes information necessary for the investigation of a criminal act, relating to individuals or to goods of the Data Controller; (b) to the competent judicial, prosecutorial and police authorities when they lawfully request data within the exercise of their duties; and (c) to the victim or the prepetrator of a criminal act, when it comes to data that may constitute evidence of the act.
5. Duration of Storage
The data is automatically deleted within fifteen (15) working days. In the event that we discover an incident during this period, we isolate part of the video and store it for up to one (1) month, with the aim of investigating the incident and initiating legal proceedings to defend our legal interests, while, if the incident concerns a third party, we store the video for up to three (3) more months.
6. Rights of Data Subjects
Data subjects have the following rights:
- Right of access: you have the right to know whether we are processing your image and, if so, to receive a copy of it.
- Right to restriction: you have the right to request restriction of the processing, such as not to delete data that you consider necessary to establish, exercise or support legal claims.
- Right to object: you have the right to object to the processing.
- Right to deletion: you have the right to request your data to be deleted.
You may exercise your rights by sending an e-mail to [email protected] or by registered letter to our postal address or by submitting the request in person to us at our premises’ address. In order for us to consider a request related to your image, you will need to tell us when, approximately, you came into range of the cameras and provide us with a picture of you to help us identify your own data and secrete the data of third-party images. Alternatively, we give you the option to come to our premises so that we show you the images in which you appear. We also point out that the exercise of the right to object or deletion does not imply the immediate deletion of data or the modification of processing. In any case, we will respond to you in detail as soon as possible, within the deadlines set by the GDPR.
7. Right to file a complaint
If you consider that the processing of your data violates Regulation (EU) 2016/679, you have the right to file a complaint with the supervisory authority.
The competent supervisory authority in Greece is the Data Protection Authority, 1-3, Kifisias Str, 115 23, Athens, https://www.dpa.gr/ , tel no. 2106475600.