Level B Update on the Processing of Personal Data through Video Surveillance System.

1. Details of the Data Controller

The company under the name "FIVE DOORS I.K.E.", which has a VAT number 801323882 and a G.E.M.I. number 154409504000, is registered with the Tax Office Z' of Thessaloniki and is located at 2 Straitsa Street (P.O.: 57001), with email: 5doorscontact@gmail.com.

 

2. Purpose of Processing and Legal Basis

We use a surveillance system for the purpose of protecting persons and property. The processing is necessary for the purposes of legitimate interests that we pursue as Data Controller (Article 6(1)(f) GDPR).

 

3. Interest analysis

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3.1 Our legitimate interest consists in the need to protect our premises and the goods on them from unlawful acts, such as, but not limited to, damage to other people's property and theft. The same applies to the safety of the life, physical integrity, health and property of our occupants, as well as third-party visitors, who are lawfully present in the premises under surveillance. 

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3.2 The recording system operates 24 hours/24 hours a day, 7 days a week.

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3.3 We collect only image data, with recording and storage for a specific period of time. The video surveillance system operates in each apartment building in which we provide apartment rental services to you, only if we have posted warning signs of video surveillance system operation. Please note that we have limited the recording exclusively to the area where we have assessed that there is an increased likelihood of illegal acts (e.g. theft) being committed. In particular, the recording starts to take place before the entrance door to the building, without focusing on areas where the privacy of the persons whose image is taken may be unduly restricted, including their right to respect for personal data. The indoor camera shall record exclusively the common interior space of the entrance of the building, the common area of the basement (if the building has one), as well as the ground floor terrace (if the building has one). The exact location of the cameras is indicated by the location of the warning signs.

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3.4 Closed circuit television (CCTV) cameras do not have a focus (zoom) capability and do not collect audio data.

 

4. Access - Transmission

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4.1 Access to the Closed Circuit Television (CCTV) system recorder is granted to a specific group of persons. The material held is accessible only by the Management of the Controller, and any external contractors contracted by us and bound by us under processing agreements under Article 28 of the GDPR, who are (or may be in the future) charged with the custody and security of the site. 

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4.2 The transmission of data collected by CCTV to third parties is generally only permitted with your prior notification and only if the requirements of European and Greek legislation on personal data protection, as applicable, are met. This material is transmitted to third parties in the following cases: a) to the competent judicial, prosecutorial and police authorities when it contains data necessary for the investigation of a criminal offence involving persons or property of the controller; b) to the competent judicial, prosecutorial and police authorities when they lawfully request data in the exercise of their duties; and c) to the victim or perpetrator of a criminal offence when it concerns data which may constitute evidence of the offence.

5. Lead time

We keep the data, to which this Notification (CCTV) refers, for twelve (12) days, after which it is automatically deleted. In the event that during this period we detect an incident, we will isolate part of the video and keep it for up to one (1) month more, in order to investigate the incident and initiate legal proceedings to defend our legal interests, while if the incident involves a third party we will keep the video for up to three (3) months more.

 

6. Rights of Data Subjects

The Data Subjects have the following rights in relation to the processing to which this Communication (CCTV) relates:

• 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 ask us to restrict processing, such as not deleting data that you consider necessary for the establishment, exercise or maintenance of legal claims. 

• Right to object: you have the right to object to processing. 

• Right to erasure: you have the right to request that we erase your data. 

You can exercise your rights by sending an e-mail to 5doorsdpo@gmail.com or a letter to our postal address or by submitting your request to us yourself at our offices. In order for us to consider a request relating to your image, you will need to identify approximately when you were in range of the cameras and provide us with an image of you to assist us in identifying your own data and in masking the data of third party subjects. Alternatively, we give you the option of coming to our premises to show you the images in which you appear. We also point out that exercising the right to object or erasure does not imply the immediate deletion of data or the modification of processing. In any case, we will reply to you in detail as soon as possible, within the time limits set by the GDPR.
 

7. CCTV archive: 

The "Processing Manager" shall keep a record of requests for the processing of CCTV data relating to you at its offices. The "Controller" shall also keep a file in which the following are described and included: (a) the technical characteristics of the cameras; (b) a diagrammatic representation of the location of the cameras; (c) the place where the data collected by the closed circuit television (CCTV) is kept. 
 

8. Changes to this Update: 

The Company reserves the right to amend and update this Update at any time and without notice. In any such case, you will be notified of the changes as soon as practicable. In case you have any questions or queries regarding this Update or more generally regarding the protection of your personal data, you may contact the Data Protection Officer (dpo) at e-mail: 5doorsdpo@gmail.com.

9. Right to lodge a complaint:

If you believe that the processing of your data is in breach of Regulation (EU) 2016/679, you have the right to lodge a complaint with a supervisory authority.  The competent supervisory authority for Greece is the Hellenic Data Protection Authority, Kifissias 1-3, 115 23, Athens, Greece, https://www.dpa.gr, tel. 2106475600.