Information about closed-circuit television (CCTV) systems
SHIPS JOINT VENTURE IGOUMENITSA CORFU PAXOI (hereinafter referred to as "KERKYRA SEAWAYS")
Information on the existence of a System of Closed Circuit television (“CCTV”)
Privacy Notice on processing of personal data through a video surveillance system (CCTV)
1. Data Controller:
KERKYRA SEAWAYS, having its registsred offices at 7, Ioniou Pelagous strt, Post Code 46100 Igoumenitsa Greece e-mail: [email protected], Tel. No: +30-……………..
2. Data Protection Officer (DPO):
Mr. …. or Mrs………………………. E-mail [email protected].
3. Purpose and legal basis of the data processing:
We use CCTV system as to protect our offices, our ships sailing under our joint venture scheme, natural persons or/and goods (security). Processing is absolutely necessary for the purpose of the legitimate interests we pursue as a data controller (article 6 para. 1. (f) GDPR) and / or an under the law relevant obligation to take precautionary measures for our offices and ships (e.g. obligation of owner, ship-owner, ships exploitators etc.), as this arises or imposed each time by an applicable law.
4. Analysis of the Legal interests .
Our legal interest is required as to protect our premises as detailed above and the goods included against potential illegal actions, such as, indicatively, thefts, vandalism. The same applies for the preservation of life safety, physical integrity, health, as well as the personal property and belongings of our personnel and of third parties lawfully located each time in the areas under surveillance. We only collect image data and limit the surveillance to places where we have previously assessed that there is an increased possibility of illegal actions , for example thefts, on the ships cashiers, or at the entrance of our premises, without focusing on places where privacy of the persons captured by the CCTV may be severely restricted, including their right to respect of their personal data.
The CCTV material held is accessible only by our competent / authorized personnel in charge of security as detailed above. Such material is not disclosed to third parties without the consent of the data subject, except in the following cases: (a) before the competent Judicial, Prosecutorial, Police and Port Police Authorities when it contains information necessary to investigate a criminal offense involving persons or goods of the data controller; (b) to the competent Judicial, Prosecutorial, Police Port Police Authorities when lawfully requesting data during the performance of their duties, and (c) to the victim or perpetrator of a criminal offense, in the case of data which may constitute evidence of the illegal action.
6. Time for the Data Retention
We maintain the data of the building premises for three (3) days, following which, they are automatically deleted. On the ships, we keep the data for as long as such is provided by the statutory Safety Regulations and in accordance with the principles of proportionality and minimization for a time period not exceeding fifteen (15) days. In the event that during these periods an incident occurs, we isolate part of the video and maintain it for one (1) more month, in order to investigate the incident and initiate the relevant legal proceedings to defend our legal interests, while if the incident concerns third parties, we will keep the video for up to three (3) more months.
In particular, it is pointed out that, in case of video surveillance systems installed on ships, some of them monitor the movements of individuals in real time, without storing and recording the data received.
7. Rights of the Data subjects
Data subjects have the following rights:
- The Right of access: you have the right to know if we process your image and if so, to receive a copy of it, if the image is recorded..
- Right to limit the process: you have the right to request from us to limit processing, for example, you may ask from us not to delete data that you deem necessary to establish, exercise or support legal claims.
- Right of Objection: you have the right to object to the processing.
- Right to demand erasing: you have the right to request that we erase your personal data.
You may exercise your rights by sending an e-mail to: [email protected] or a letter to our postal address 7, Ioniou Pelagous str., 46100 Igoumenitsa GReece, or by submitting the request to us in person, at the above address of the Company. To examine a request related to your image, you should tell us when you were within the range of the cameras and give us a picture of you in order for us to be able to locate your data and hide the data of third parties pictured. Alternatively, you have the potentiality to visit our premises to show you the images in which you appear. We hereby note, that exercising the rights of objection or erasing does not imply the immediate erasure of data or the modification of the processing. In any case, we will answer you in detail as soon as possible, within the deadlines set by the GDPR.
8. Right to file a complaint
In case you consider that the processing of your data violates Regulation (EU) 2016/679, you have the right to file a complaint with the competent Supervisory Authority. The competent Supervisory Authority in Greece is the Hellenic Data Protection Authority, 1-3 Kifisias Avenue, 11523, Athens, https://www.dpa.gr/, telephone number +30-210-6475600.