Policy regarding the surveillance using video means ff the tenement located in Targu Mures, 4/A2 Livezeni St.
NORMATIVE REFERENCES AND LEGITIMITACY CONDITIONS
a) Law no. 333 dated July 8th 2003 regarding the security of objects, assets, valuables and the protection of the persons, with the later on amendments and additions;
b) Resolution no. 301 dated April 11th 2012 for the approval of the Methodological Norms of the Law no. 333/2003 regarding the security of objects, assets, valuables and the protection of the persons
c) Law no. 677/2001 for the protection of the persons with regard to the processing of the personal data and the free circulation of such data, with the later on amendments and additions;
d) Order no. 52 dated April 18th 2002 regarding the approval of the Minimum security requirements for the personal data processing;
e) ANSPDCP ruling no. 52 dated May 31st 2012 regarding the personal data processing by using video surveillance means;
f) Instructions of the European Authority for the Protection of the Personal Data relating to video surveillance, published on March 17th 2010, Brussel;
g) Internal regulation;
h) Job descriptions.
• The policy is applied within the surveillance activities using video means. The usage of the video system is necessary for the good administration and functioning of the SC Partner ALU Plast SRL, especially in order to control the safety and security.
• The policy regarding the surveillance through video means describes the video system of the SC Partner ALU Plast SRL and the protection means carried out by it in order to protect the personal data, private life and other fundamental rights such as the legitimate interests of the persons filmed by the cameras.
• The present policy regarding the surveillance through video means can be accessed via the website www.ferestrepartner.ro.
This policy establishes:
a) A unitary set of rules which regulates the implementation and usage of the video surveillance system with the aim of insuring the safety of the persons and of the assets, guarding and protection of the assets, tenements and values upon the property of the SC Partner Alu Plast SRL, while respecting the company's obligations and security measures adopted for the protection of personal data, the protection of privacy, legitimate interests and the safeguarding of the fundamental rights of the data subjects.
b) The responsibilities regarding the administration and exploitation of the surveillance system via video means, as well as those regarding the drafting, certification and approval of the documents afferent to these activities.
The video usage policy is available on the SC Partner Alu Plast SRL website
A periodic review will be carried out annually by the structures responsible for security and will re-analyze:
(i) the need to maintain the system in use;
(ii) accomplishment of the declared purpose;
(iii) possible appropriate alternatives to the system and
(iv) this policy is still in line with Law 677/2001
SC Partner Alu Plast SRL uses a video surveillance system with the aim of securing and controlling the access. With the help of this system it monitors the access within the compound of the SC Partner Alu Plast SRL, it insures the safety of the assets and the security of the persons – employees of the SC Partner Alu Plast SRL or the visitors /clients, as well as of the properties and information held.
The video surveillance system completes the other physical security measures, such as the control access system main entrance door and helps to prevent, combate and, if any, the research of the physical unauthorized access to the secured spaces and to the rooms occupied by the clients of the SC Partner Alu Plast SRL. In addition, the video surveillance system helps to prevent, detect and investigate the thefts of assets held by the SC Partner Alu Plast SRL, assets held by the clients of the SC Partner Alu Plast SRL or the prevention, detection and the investigation of the risks and threats to the employed personnel which carries out its activity at the surveyed location. The video surveillance system is not used for another purpose than that communicated, is not used in the monitoring of the employees’ activity or in the attendance sheet. Moreover, the system can constitute a mean of investigation or obtaining some information for internal investigations or disciplinary procedures, including in the case in which an incident of the physical security is produced or it is observed a criminal behaviour (in exceptional circumstances the images can be communicated to the investigation bodies within a disciplinary or criminal investigation).
The video surveillance system comprises: the building located in Targu Mures, str. Livezeni nr. 4 / A2: showroom, office floor, production hall, production / warehouse hall, car park.
By video means it is surveyed:
-the access areas and the spaces destined to the employees and visitors;
-areas with restricted access;
-surroundings of the buildings in order to protect the exterior spaces;
• The placement of the cameras was closely revised in order to insure the limiting as much as possible of the monitoring of the areas which do not present interest for the purpose pursued.
• There are not monitored the areas in which there is a high level of expectations regarding the private life, such as the rooms rented to the clients in a hotel regime, washer room /service, dining room, office/kitchen, bathrooms and other similar locations.
• Exceptionally, in the case in which some necessities relating to the security adequately justify it, cameras can be installed in such places, yet only after an impact evaluation is carried out and only after informing the person in charge with the protection of the personal data. In such cases, a specific announcement will be placed and made visible in the said places.
PERSONAL DATA COLLECTED VIA THE VIDEO SURVEILLANCE
• The video system of the SC Partner ALU Plast SRL a does not have as aim the capture (for example, through selective focalisation or orientation) or image processing (for example, indexing, profile creation) which reveal „the special data categories”.
• SC Partner ALU Plast SRL does not intend to use the surveillance system and, in an ad hoc manner, namely, with a temporary feature, of circumstance.
Description and technical specifications of the system
• Conventionally, the video surveillance system is a static system. It has as function the recording of images and is equipped with movement sensors. The system can register any movement detected by the cameras installed in the surveyed area together with the date, hour and location. All the cameras are functional 24 hours, 7 days per week. When necessary, the quality of the images allows for the recognition of those which pass through the action area of the cameras. For a higher degree of safety of the data processing which can be obtained following the video surveillance, the cameras are fixed (without zoom function), thus the user cannot modify the perimeter /aim of the surveillance. The specially trained operators must abide with the confidentiality settings and the access rights.
• There is no inter-connection with other systems and it does not record the sound.
Benefits of the surveillance system
• Increased control in the surveyed perimeter, entrances and exits;
• Restriction of access of the foreign persons;
• Removing the losses caused by unforeseen events;
• Abiding by the norms and legislation in force for objects with risk.
PROTECTION OF THE PRIVATE LIFE AND OF THE INFORMATION SECURITY
In order to protect the security of the video system and in order to increase de degree of protection of life, the following technical and organisational measures have been introduced:
• limiting the storage time of the filmed material, according to the security requests;
• storage medias (the servers on which the recorded images are stored) are located in secured spaces, protected by physical security measures;
• all the users with access right have signed confidentiality statements through which they undertake to abide by the legal provisions in the field;
• the access right is granted to the users based on the need to know, only for those resources strictly necessary for accomplishing the service tasks;
• all the members of the personnel (both external and internal) sign confidentiality agreements.
Only the property’s manager has the right to award, amend or cancel the access right of the users according to the general access procedure to the database. He/she permanently keeps an updated list of all the persons with the right to access the video surveillance system, with the specification of the type of access.
ACCESS TO THE PERSONAL DATA AND THEIR REVEALING
The access to the stored images and/or the technical architecture of the video surveillance system is limited to a reduced number of persons and is established by the attributions specified in the internal decisions of the SC Partner Alu Plast SRL (with what purpose and what type of access). Especially, SC Partner Alu Plast SRL imposes limits regarding the persons who have the right to:
• View the material filmed in real time: the imagines which unfold in real time are accessible to the persons responsible designated to carry out the surveillance activity;
• View the recording of the recorded material: viewing the recorded images will be done in justified cases such as the cases foreseen expressly by the law and the security incidents, by the specially designated persons;
• Copy, download, delete or change any filmed material.
• All members of staff with access rights receive initial training in data protection. This procedure will be integrated into the training and guidance program for all users with access rights and tasks in the operation of the video surveillance system.
After training, each participant signs a confidentiality statement.
Disclosure of personal data
• Any activity of disclosing personal data to third parties will be documented and subject to rigorous analysis on the need for communication and on the other hand the compatibility between the purpose of the communication and the purpose for which it was originally collected for processing (security and access control). Any disclosure situation will be recorded by the system administrator in a Disclosure Record Register.
• SC Partner Alu Plast SRL has the obligation to make available to the judicial authorities, upon their written request, video recordings in which criminal offenses are committed.
• The video surveillance system is not used to check for attendance at the program or to assess workplace performance. In exceptional cases, but subject to the safeguards described above, access to the Disciplinary Commission may be granted in a disciplinary investigation, provided that the information helps investigate a criminal offense or disciplinary offense that would be prejudicial to a person's rights and freedoms.
• Any breach of security with respect to cameras is indicated in the investigation register and SC Partner Alu Plast SRL will be informed of this as soon as possible.
• The length of time spent on video surveillance is proportional to the purpose for which the data is being processed, so the images are stored for a period not exceeding 30 days, after which they are deleted automatically by the order in which they are were recorded. In the case of a security incident, the retention time of the relevant filming material may exceed the normal limits depending on the time needed to investigate the incident further. Keeping is rigorously documented, and the need for preservation is reviewed periodically.
• If the storage life exceeds the deadline set in this policy, it will be recorded in the Records Register over the storage time, managed by the system administrator.
RIGHT OF THE AIMED PERSON
SC Partner Alu Plast SRL guarantees that it insures the abiding of the rights which accrue to the aimed persons, according to the law. All the persons involved in the video surveillance activity and those responsible for the management of the filmed images will abide by the Personal data access procedure.
Informing the aimed persons
• The primary information of the aimed persons is done in a clear and permanent manner, through an adequate sign, with sufficient visibility and localised in the monitored area such that it signals the existence of the surveillance cameras, but also to communicate essential information regarding the personal data processing.
• The persons aimed are cautioned about the existence of the video surveillance system through the Internal rules of the company which comprises also the aim of the processing and identifies SC Partner ALU Plast SRL as operator of the collected data through the intermediation of the video surveillance.
Exercising the rights to access, intervention and opposition
During the entire storage period of the personal data, the aimed persons have the right to access the personal data which they see as being held by the SC Partner ALU Plast SRL, to request the intervention (deletion/updating/rectification/anonymisation) or to oppose the processing, according to the law.
Any request to access, rectify, block and/or delete the personal data following the usage of the video cameras must be addressed to the SC Partner ALU Plast SRL.
The answer to the request for access, intervention or opposition is given within 15 calendar days. If this term cannot be abided by, the aimed person will be informed with regard to the reason for the delay of the answer, moreover, he/she will be communicated also the procedure which will follow for the solving of the request.
If there is an express request of the aimed person, it can be granted the right to visualise the recorded images which concern him/her or a copy of them can be sent. The images provided will be clear, to the extent it is possible, with the condition that it does not prejudice the rights of the third party (the aimed person will be able to visualise only his/her own image, the images of other persons which might appear in the recording will be edited such that it will not be possible their recognition/identification). In the case of such a request, the person aimed at is obliged to identify himself/herself beyond any suspicion (to present an identity card when participating to the viewing), mention the date, hour, location and surroundings in which he/she was recorded by the surveillance cameras. Moreover, the aimed person will present also a recent photo such that the designated users can more easily identify him/her in the filmed images. The person will be able to identify only his/her image, those of the persons which appear in the recording will be edited such that it will not be possible their recognition/identification.
There exists the possibility of refusing the right to access in the case in which the exceptions foreseen by the law apply. The requirement for restricting the access can be imposed also in the case I which there exist the obligation to protect the rights and freedoms of some third parties, for example, if in the images appear also other persons and there is no possibility to obtain their consent or they cannot be extracted, by editing the images, irrelevant personal data.