Video Surveillance Privacy Statement
PRIVACY STATEMENT FOR VIDEO SURVEILLANCE SYSTEMS (PURSUANT TO LEG.DECREE No 196/2003 AS AMENDED BY LEG. DECREE No 101/2018, ART.13 REGULATION (EU) 679/216 AND GUIDELINES 3/2019 OF THE EUROPEAN DATA PROTECTION BOARD
In compliance with the Italian Data Protection Authority, (Art. 3.1 Prov. 08.04.2010) and the Guidelines of 3/2019 on processing of personal data through video devices adopted on 29 January 2020 by the European Data Protection Board (EDPB), we wish to inform you that there is an active video surveillance system in place in this clinic in order to prevent any damage to property and/or persons, possible theft from guests, visitors and external collaborators and, more generally, to guarantee the safety of the users of the facility as well as its premises.
Under the regulations on the protection of personal data (Leg. Decree No 196/2003 as amended by Leg. Decree No 101/2018, Privacy Code, and Art.13 Regulation (EU) 679/216 and EDPB Guidelines 3/2019), this processing will be based on the principles of fairness, lawfulness and transparency and protection of your privacy and your rights.
Pursuant to Article 13 Regulation (EU) 679/216, we hereby inform you that:
Purpose of Processing
The clinic has installed a video surveillance system on its premises and wards in compliance with the data protection regulations and, in particular, with the Provision of 8 April 2010 of the Italian Data Protection Authority and the EDPB Guidelines 3/2019. The installation of the video surveillance system responds to the needs and purposes of preventing any damage to property and/or persons, possible theft from guests, visitors and external collaborators and, more generally, to guarantee the safety of the users of the facility as well as its premises.
The data is processed in accordance with the methods and data requirements set out in Leg. Decree No 196/2003 and subsequent amendments and according to the General Provisons of the Italian Data Protection Authority 08.04.2010 and the EDPB Guidelines 3/2019 and will include all operations or set of operations provided for by Art. 4(1)(a) of Reg. (EU) 679/2016; operations necessary for the processing in question, including communication to the persons referred to in the next section of this statement.
The data is processed:
- with the use of electronic tools and managed by specially appointed personnel;
- data will be stored on a computer.
The retention of the images acquired by the video surveillance system shall be limited, in compliance with the provisions of the law, to 72 hours following their collection, which, on public holidays, shall begin at 00:00 hours the next working day. At the end of the retention period, the images shall be deleted from the system; this is without prejudice to any requirements arising from the need to comply with specific investigative requests by the judicial authorities or the judicial police.
The Clinic has put in place security procedures regarding access to the recording servers (using passwords).
Before entering the areas concerned, there are signs displayed warning of the video surveillance system installed in the clinic, so that the data subject is duly informed before being filmed.
In the event of theft, damage and/or unlawful conduct, the personal data relating to the processing in question shall be disclosed to the competent authorities and to any persons appointed by us for the purpose of possible checks. Your data shall not be disseminated.
Compulsory/optional provision of data
Signs have been posted indicating that there are cameras installed and their range, enabling people to avoid being filmed by the system.
Rights Under ART.15 ET SEQ. of REG. (EU) 679/2016
Pursuant to Articles 15 et seq. of Reg. (EU) 679/2016, you have the right at any time to obtain confirmation as to whether or not personal data concerning you are being processed and to know its content and origin, to verify its accuracy or to request that it be completed, updated or corrected.
Any access requests made by guests, visitors and external collaborators means the recorded images, if available, referring to the period indicated by the data subject will be saved and will also be made available to the judicial authorities or judicial police in the event of a request; the exercise of the right of access results in the expiry of the 72-hour retention period, as better described under Processing Methods, and in the retention of the image for as long as is necessary to conduct investigations.
With reference to the data processed directly by our Clinic, we hereby inform you that the DATA CONTROLLER is Casa di Cura Paideia S.p.a. with registered office in Via G. Fabbroni, 6 – 00191 – Rome, VAT no 01847201009.