Video surveillance system
Information pursuant to and for the purposes of Article 13 of Regulation (EU) 2016/679 (hereinafter "GDPR") and current national legislation on the protection of personal data processing, in relation to the video surveillance system.
With this notice, AQUARDENS Wellness & Hospitality S.r.l. provides the Data Subject with the information referred to in Article 13 of the GDPR regarding the processing of personal data concerning him/her.
With regard to employees only, this policy serves as a supplement to the general employee policy.
Data Controller
The Data Controller is AQUARDENS Wellness & Hospitality S.r.l., with registered office in Via Valpolicella, 63 - 37026 Pescantina (VR)..
Data Protection Officer (DPO or RPD).
The Data Controller has appointed a Data Protection Officer (DPO/RPD). The contact details of the DPO/RPD are as follows: dpo@aquardens.it.
Purpose and methods of processing:
The video surveillance system, duly authorised in accordance with Law 300/1970 and the Trade Union Agreement of 09/10/2014, is used for the purposes of protecting property and for security reasons. Should any events occur, that may constitute criminal offences, the system will also be used to support the activities of the judicial authorities and/or law enforcement agencies.
The use of cameras will be in full compliance with Article 4 of Law 300/1970, the legislation on the protection of personal data (GDPR and current national legislation) and the Provision of the Data Protection Authority of 8 April 2010 on video surveillance, updated to Guidelines No. 3/2019 of the European Data Protection Board on the use of video surveillance systems and video tools. The processing is carried out in compliance with the rights, fundamental freedoms and dignity of the Data Subjects and is based on the principles of fairness, lawfulness and transparency. The cameras are installed and programmed in such a way as not to film areas reserved exclusively for employees (changing rooms, toilets, canteens or break areas).
Legal basis for processing
The processing is necessary for the pursuit of the legitimate interests of the Data Controller or third parties, provided that the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data do not prevail.
Mandatory or optional nature of the provision of data
The video surveillance system detects and records images of everyone who passes within its range. For this reason, there are first-level notices (i.e. signs) before entering the area under video surveillance. The provision of data is mandatory and is carried out through the voluntary act of simply accessing the video surveillance areas. Refusal to provide data can be expressed by voluntarily not accessing the video surveillance areas.
Categories of subjects to whom the data may be disclosed
The images are not subject to communication or dissemination, unless such operations are required by regulatory provisions. The data may therefore be communicated to the judicial authorities if the conditions are met.
The data provided may also be communicated to professionals and/or companies responsible for providing technical assistance and maintenance, within the limits of the provisions of current laws and regulations. In this case, these subjects will act as Data Processors pursuant to and for the purposes of Article 28 of the GDPR and current national legislation.
The complete and updated list of Data Processors is available to those entitled to it upon request at the Data Controller's headquarters.
Transfer of data abroad
Data is not transferred outside the European Union; any use of technological solutions involving the transfer of data to non-European third countries may only take place in compliance with Articles 44 et seq. of the GDPR (in the presence of adequacy decisions and/or adequate safeguards, provided that the data subjects have enforceable rights and effective remedies, or provided that one of the specific derogations provided for by the legislation applies in each case).
Storage times
The images will be stored for a period not exceeding 48 hours from their acquisition, except in cases of special requirements for further storage in relation to holidays or closures, as well as in cases where it is necessary to comply with a specific investigative request from the judicial authorities or judicial police, and in any case always in compliance with the provisions of the aforementioned Provision on video surveillance of 8 April 2010. After this period, the images are automatically overwritten.
Rights of the data subject
The data subject may exercise the rights granted by Articles 15 et seq. of the GDPR and, in particular, the right to access their personal data, request its restriction or erasure, if the conditions are met, and object to its processing by sending a request to the following email address: privacy@aquardens.it.
Right to lodge a complaint
If you think your personal data is being processed in a way that breaks the GDPR, you can complain to the Data Protection Authority (www.garanteprivacy.it), as set out in Article 77 of the GDPR, or take legal action (Article 79 of the GDPR).
