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Video surveillance
NOTICE TO THE PUBLIC REGARDING THE PROCESSING OF PERSONAL DATA
Pursuant to Art. 12 et seq. of Regulation (EU) 2016/679 ("GDPR" or "Regulation"), and in general in compliance with the principle of transparency provided for by the same Regulation, Hydro Dolomiti Energia Srl, in accordance with the Provision of the Italian Data Protection Authority of 8 April 2010, Art. 3, paragraph 1, hereby informs that video surveillance systems installed to protect company assets, property owned by employees and the safety of persons are active in the properties owned by and/or legally available to Hydro Dolomiti Energia Srl. For this purpose, it provides the following information regarding the processing of personal data.
1. DATA CONTROLLER
The data controller (“Data Controller" or "Controller") is Hydro Dolomiti Energia S.r.L - with registered office in Trento, Viale Trieste, 43, Tax Code and VAT No. 02075180220, certified email (PEC): hde.pec@hde.legalmail.it.
For contacts specifically relating to the protection of personal data, including the exercise of the rights referred to in point 9 below, the following email address is specifically provided: info.privacy@cert.dolomitienergia.it, to which you are kindly requested to address any requests you may have.
2. CONTACT DETAILS OF THE DATA PROTECTION OFFICER
Please be informed that the Data Controller, pursuant to Art. 37 of the Regulation, has designated the Data Protection Officer ("DPO") who may be contacted for any need relating to the protection of personal data, including the exercise of the rights referred to in point 9 below, at the email address: info.privacy@cert.dolomitienergia.it, telephone 0461 362222, or at the address Via Fersina 23, Trento.
3. PURPOSES OF PROCESSING
The recorded images shall be used for purposes of security and protection of company assets, employees' property, as well as to ensure protection within workplaces and their appurtenances.
4. TYPE OF DATA PROCESSED
For the purposes referred to above, the images of the data subject and vehicle registration plates, resulting from video recording equipment, may be subject to processing..
5. LEGAL BASIS OF PROCESSING
The legal basis for the processing is the legitimate interest of Hydro Dolomiti Energia Srl in protecting the security of the Company's assets and plants and ensuring the safe performance of public service activities and/or activities of national interest (electricity production).
6. METHODS OF PROCESSING AND DURATION OF PROCESSING
The processing is carried out in compliance with the methods established by the Regulation and by the provisions of the above-mentioned Provision of 8 April 2010, and shall include all the operations or set of operations indicated in Article 4, No. 2), GDPR - performed with the aid of IT systems - and specifically: collection, recording, organisation, structuring, updating, storage, adaptation or alteration, extraction and analysis, consultation, use, disclosure by transmission, comparison, interconnection, restriction, erasure or destruction of the data. Processing is carried out through the use of electronic tools, is managed by specifically appointed, authorised and/or designated personnel, and data storage, where recording takes place, is carried out on IT media. The images shall be stored for a period not exceeding 24 hours, after which they shall be automatically overwritten, without prejudice to requirements for further storage in relation to public holidays or office closures and the need to retain them by reason of specific requests from the judicial Authorities or the judicial police.
Hydro Dolomiti Energia srl has implemented adequate security procedures with regard to access to servers.
The premises and areas subject to video filming and recording are covered by information signs indicating the presence of the system, positioned near the premises and areas themselves and in any event in such a way as to inform the Data Subject before being filmed by the system.
7. COMMUNICATION OF DATA
The personal data relating to the processing in question, for the purposes indicated above, may be made accessible:
1) to employees and collaborators of the Controller or of other companies belonging to the Controller's corporate group, in their capacity, respectively, as authorised persons or as data processors;
2) to third parties (for example, providers for the management and maintenance of the video surveillance system and/or companies contracted to provide guarding and security services, etc.) that carry out outsourced activities on behalf of the Controller, in their capacity as data processors;
3) to Supervisory Authorities, public entities and public bodies (national and foreign).
The personal data thus collected are not subject to dissemination.
8. PLACE OF DATA PROCESSING
Data processing takes place within the territory of the European Union and there is no intention to transfer the personal data to a country outside the European Union or to an International Organisation.
9. RIGHTS OF THE DATA SUBJECT
The GDPR grants the Data Subject the exercise of the following rights with reference to the personal data concerning him or her (the summary description is indicative; for the complete statement of the rights, including their limitations, reference is made to the Regulation, and in particular to Articles 15-22):
- access to personal data (the right to obtain, free of charge, information regarding the personal data held by the Controller and the related processing, as well as to obtain a copy in an accessible format);
- rectification of data (correction or integration of data - not expressing evaluations - that are incorrect or inaccurate, including where they have become so because they are not up to date);
- withdrawal of consent (where the processing is carried out on the basis of consent given by the data subject, such consent may be withdrawn at any time, without affecting the lawfulness of the processing carried out prior to withdrawal)
- erasure of data (right to be forgotten) (for example, the data are no longer necessary in relation to the purposes for which they were collected or processed; they have been unlawfully processed; they must be erased in order to comply with a legal obligation; withdrawal or objection to the processing has occurred);
- restriction of processing (in certain cases - contesting the accuracy of the data, for the time necessary for verification; contesting the lawfulness of the processing with objection to erasure; need for use for the data subject's defence rights, while they are no longer useful for the purposes of the processing; if there is an objection to the processing, while the necessary checks are being carried out - the data shall be retained using methods such that they may, where applicable, be restored, but, in the meantime, shall not be accessible by the Controller except precisely in relation to the validity of the restriction request submitted by the data subject);
- objection in whole or in part to the processing (in certain circumstances, and in any case where the personal data are processed for direct marketing purposes, the Data Subject has the right to object at any time to the processing, including profiling to the extent that it is related to such direct marketing);
- data portability (where processing is based on consent or on a contract and is carried out by automated means, upon request, the Data Subject shall receive, in a structured, commonly used and machine-readable format, the personal data concerning him or her and may transmit them to another Data Controller, without hindrance from the Data Controller from whom he or she was provided them and, where technically feasible, may obtain that such transmission be carried out directly by the latter);
- lodging of a complaint with the supervisory authority (Italian Data Protection Authority).