{"id":4292,"date":"2021-03-29T06:49:53","date_gmt":"2021-03-29T03:49:53","guid":{"rendered":"https:\/\/alimos-marina.gr\/cctv\/"},"modified":"2024-02-01T11:00:20","modified_gmt":"2024-02-01T09:00:20","slug":"cctv-policy","status":"publish","type":"page","link":"https:\/\/alimos-marina.gr\/en\/cctv-policy\/","title":{"rendered":"POLICY OF RECORDING PERSONAL DATA VIA VIDEO SURVEILLANCE SYSTEM"},"content":{"rendered":"

The herein Policy describes the terms and conditions, under which a closed circuit television system (CCTV system) has been installed and is in function in Alimos Marina by the company\u00a0“DEVELOPMENT OF NEW ALIMOS MARINA CONCESSION SINGLE MEMBER SOCIETE\u00a0<\/strong>ANONYME” <\/b>and with the distinctive title\u00a0\u201cDEVELOPMENT OF NEW ALIMOS MARINA SINGLE MEMBER S.A.\u201d<\/strong>(based in Kifissia, Attica, 25 Ermou Street, VAT Number 801197209, Trade Registry number \u00a0No. 151536301000), (hereinafter the “Company”).
\nThe Company has concluded the Concession Agreement dated 13-05-2020, granted the right to use, operate, manage and exploit the mobile\u00a0 and \/ or real estate\u00a0 assets within the land and \/ or sea zone of Alimos Marina, for a time period of forty (40) years (the “Project” or “Concession”) with the Hellenic Republic Asset Development Fund (“HRADF”), the Greek Republic (“GR”) and the Hellenic Public Properties Company (HPPC), under the specific terms and conditions described in the Concession Agreement and in the other contractual documents that have been signed for the Project, whereas since 01\/01\/2021 (“Date of Commencement of the Concession”), the company “DEVELOPMENT OF NEW ALIMOS MARINA SINGLE MEMBER S.A.” is the successor party for the operation and management of Alimos Marina.
\nThis Policy of recording personal data via video surveillance system (hereinafter the “Policy”), aims to provide information and further briefing to visitors\/users\/customers\/counterparties\/ employees of Alimos Marina (hereinafter “the Users”) regarding the process of their personal data, due to the aforementioned video surveillance system. Moreover, this Policy includes a description of the rights of Users of Alimos Marina, regarding the protection of their personal data and also explains what\u00a0 kind of personal information the Company collects in this context, and how this data is handled.<\/p>\n

\u0391<\/strong>. FIELD OF APPLICATION \u2013 SCOPE<\/strong><\/p>\n

The installed video surveillance system (CCTV) records the motions of the incoming data subjects, in the area of \u200b\u200bAlimos Marina as analyzed below:
\nThe circuit is installed only to protect people and property.
\nAudio recording capacity is not enabled.
\nThe video surveillance system is not used to monitor employees at their workplace or to record the movements and habits of the Users of Marina, except for easier monitoring and security in its public areas, where, due to the high value of assets located within the Marina, it is obligatory \u00a0to take measures, such as monitoring he area through\u00a0 video surveillance system, in order to achieve the protection of goods, merchandise, assets and persons in the supervised area of \u200b\u200bAlimos Marina.<\/p>\n

\u0392<\/strong>. DATA CONTROLLER<\/strong><\/p>\n

The Company is the Controller of your personal data, received through the video surveillance system, according to the General Regulation 2016\/679 of the European Union (General Data Protection Regulation, hereinafter referred to as “GDPR”), Law 4624\/2019, as in force, the relevant Guidelines \u00a0of the Hellenic Data Protection Authority(HDPA) (Guideline 1\/2011 “Use of video surveillance systems for the protection of persons and property”) and the relevant Guidelines of the European Data Protection Board (Guideline 3\/2019 on processing of personal data through video devices).
\nThe Company has installed in several key spots in the public areas of Alimos Marina, \u00a0informatory signs, \u00a0according to the standards and relevant guidelines of the Hellenic Data Protection Authority, where the Users of Marina are thoroughly informed about the spots, \u00a0where recording cameras have been installed, as well as about the contact details of the Company, so that anyone shall send a query, \u00a0regarding the process of his personal data (see below under H).
\nThe Company processes the absolutely necessary data (data minimization) for the protection of goods and persons in the supervised area of \u200b\u200bAlimos Marina and does not process additional personal data, for scopes \u00a0other than the predetermined and described above.<\/p>\n

C. LEGALBASIS FOR THE DATA PROCESS<\/strong><\/p>\n

The legal basis for the process of personal data, which is recorded via the video surveillance system, is articles \u00a06.1.c and f of the General Data Protection Regulation (GDPR). The process is mandatory for the Controller\u2019s compliance with his legal obligation, as per \u00a0the proper preservation and protection of the vessels, docking \u00a0in Alimos Marina (art. 3 of the General Regulation of Operation of Tourist Ports, Joint Ministerial Decision no. T\/9803, no. 1323 B\u2019\/16-09-2003Government Gazette), as well as for the purposes of the legal interests pursued by the Company (protection of persons and property in case of illegal events).
\nThe area \u00a0of Alimos Marina and the goods located within, must be constantly protected from illicit \u00a0acts, such as cause of body harm \u00a0or material damage to the port facilities, adjacent vessels, port equipment and personnel or to persons or\u00a0 third parties assets. The same applies to the safety of life, physical composure, health, as well as to \u00a0the property of staff and third parties, \u00a0legally placed \u00a0in the supervised area.
\nThe process of personal data is limited to the minimum, absolutely necessary extent, in order to achieve the a for mentioned scope \u00a0of process, i.e. only data of image is collected and the recording \u00a0is limited only to areas, which, due to the existing circumstances, are perceived\u00a0 as highly dangerous for illicit acts to take place, e.g. theft.
\nIt is expressly noted that, on areas where the privacy of the recorded persons, may be severely restricted, under no circumstances takes place camera focus, \u00a0and generally, when there may be high \u00a0possibility of excessive interference with the personal data of \u00a0the Users of Marina. Finally, upon balancing the interests of the\u00a0 persons, whose personal data may be processed, and the legal interest of the Controller for the safety \u00a0of the supervised area \u00a0and the protection of the appearing persons\u2019 rights, in case of danger, due to the previously mentioned, the latter \u00a0seems to prevail.<\/p>\n

D. PROCESSOF DATA \u2013 THE PROCESSOR<\/strong><\/p>\n

The process of the recorded personal data obtained via the video surveillance system, has been assigned by the Company, as the Controller, to the company \u201cHigh Protection.\u201d (hereinafter referred to as \u201cG4S\u201d), based in Eleusina, Attica, at El.Venizelou Street no. 15, P.C. 19200, with Trade Registry no. 009523501000, VAT no. 997731028 Tax Office: Eleusina). The company High Protection processes the recorded data as the Processor, under a contract signed between the Company and High Protection, where the terms and obligations of the parties, regarding the process of personal data, as set out in Articles 24 and 28 of GDPR, are thoroughly reported.
\nThe access to the recording material, is restricted to Company\u2019s and High Protection\u2019s employees, specially authorized for that scope, whereas only specific and authorized employees of the Company and High Protection, have the permission to watch live footage.
\nThe employees who are authorized to monitor the recording system, are aware of the scope of the process and the permitted use of personal data recorded by the video surveillance system, and are bound by relevant confidentiality and discretion clauses.
\nIn any case, the personal data recorded, are not disclosed or transmitted to third parties, except only upon consent of the persons depicted in the relevant log files.
\nExcluding the aforementioned, your data may be transferred to public authorities as well as to other third parties, when required by applicable law, including the Company\u2019s compliance with court decisions, and in the occurrence of illicit acts, where the competent judicial, prosecuting, police and \/ or port authorities, within the framework of their responsibilities, legally request data, which are useful in the context of investigation and preliminary examination of the above acts. In any case, the Company\u2019s Data Protection Officer is immediately, respectively informed.<\/p>\n

\u0395<\/strong>. DATA RECORDING THROUGH THE VIDEO SURVEILLANCE SYSTEM<\/strong><\/p>\n

For the surveillance of the facilities of Alimos Marina, digital (IP) fixed bullet cameras, as well as mobile cameras (PTZ) with rotating capability, which support software for embedding image analysis algorithms (Video Content Analytics) and which compose \u00a0the video surveillance system of the Marina, have been installed and are in use\u00a0 since 01\/01\/2021.
\nThe aforementioned \u00a0cameras do not record sound while, mainly, they monitor the docks of boats (piers and quays), the \u00a0land area where the boats are located during winter period, and the surrounding area of \u200b\u200bthe Marina\u2019s Headquarters. The data recorded \u00a0consist of visual data. The data and the control of the system, end up in a properly configured space at the Headquarters of the Marina, where the Control Room is located, in which the respective equipment for data collection-recording and camera surveillance are located, together with the work position of the guard-operator. The network allows the transfer of an image, received from each camera, in real time, directly to the equipment of the control center. The video-image data are encoded through \u00a0a compression algorithm and saved in the storage media.
\nThe retention period of the \u00a0personal data recorded by the video surveillance system is ten (10) days<\/strong>, except in cases of acts against a person or property, where the respective \u00a0personal data for the specific event, are kept in a separate file for thirty (30) days.
\nUpon the expiration of the retention period, ie after the expiration of the aforementioned \u00a0ten (10) days, the personal data that have been recorded, are automatically erased.<\/p>\n

F. DATA SECURITY MEASURES<\/strong><\/p>\n

The Company, in the context of the specific process of personal data, has taken the following applicable Data Security Measures:<\/p>\n