Video Surveillance Policy
REGULATORY REFERENCES AND CONDITIONS OF LEGITIMACY
1) Law no. 333 of July 8, 2003, on the protection of objectives, assets, values and protection of persons, as subsequently amended and supplemented;
2) Decision no. 301 of April 11, 2012 for the approval of the Methodological Norms of Law no. 333/2003 on the protection of objectives, assets, values and protection of persons;
3) Law no. 677/2001 for the protection of individuals with regard to the processing of personal data and on the free movement of such data, as subsequently amended and supplemented;
4) Order no. 52 of April 18, 2002 on the approval of the Minimum Security Requirements for the processing of personal data;
5) ANSPDCP Decision no. 52 of May 31, 2012 on the processing of personal data through the use of video surveillance means;
6) Instructions from the European Data Protection Supervisor on video surveillance, published on 17 March 2010 in Brussels;
7) Internal Regulations;
8) Job descriptions.
• The policy described on this page applies in the context of video surveillance. The use of the video system is necessary for the proper administration and operation of the activity of S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L., especially in order to supervise the game of escape room , but also for security and guard control.
• The video surveillance policy describes the video system of S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. and the protection measures taken to protect personal data, privacy and other fundamental rights as well as the legitimate interests of those filmed by the cameras.
CONTENT AND PURPOSE OF THE PROCEDURE
This policy states:
1) A unitary set of rules governing the implementation and use of the video surveillance system in order to ensure the proper conduct of the escape room game, in order to ensure the safety of persons and property, security and protection of property, property and values of S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L., while respecting the company’s obligations and the security measures adopted to protect personal data, protect privacy, legitimate interests and guarantee the fundamental rights of data subjects.
2) Responsibilities regarding the administration and operation of the surveillance system by video means, as well as those regarding the preparation, endorsement and approval of the documents related to these activities.
• The policy on the use of video systems is available on this page, and a regular review will be undertaken by the structures responsible for ensuring security and will review:
a) the need to keep the system in use;
b) fulfillment of the declaring purpose;
c) possible suitable alternatives to the system;
d) compliance with the law.
SC EXTENDED REALITY ESCAPE ROOMS S.R.L. uses the video surveillance system in order to carry out the activity well, but also for safety and security purposes. With the help of this system, the game of the teams in the escape rooms is supervised, clues are given, interventions are made in special cases, access to the premises is monitored, security of goods and safety of persons (employees of SC EXTENDED REALITY ESCAPE ROOMS SRL and visitors / customers ), as well as the properties and information held.
The video surveillance system complements the other physical security measures and helps prevent and combat accidents during the game, but also to prevent and combat and, if necessary, investigate unauthorized physical access, including unauthorized access to secure spaces. In addition, the video surveillance system helps prevent, detect and investigate thefts of property owned by S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. or to prevent, detect and investigate risks and threats to customers and employees operating at the supervised location. The video surveillance system is not used for any purpose other than that notified, it is not used to monitor employee activity or timekeeping. Furthermore, the system may be a means of investigating or obtaining information for internal investigations or disciplinary proceedings, including in cases where a physical security incident occurs or criminal behavior is observed (in exceptional circumstances images may be transferred to law enforcement agencies, in a disciplinary or criminal investigation).
The video surveillance system comprises certain areas of the space intended for the activity.
It is monitored by video means:
• Themed game rooms:
– The Sphinx Riddles (Egypt)
– Temple of Sacrifice (Aztec Empire)
– Twin Cities (London and Tokyo)
– The End of Time (Cosmos)
• Reception and waiting area;
• The location of the rooms has been carefully revised to ensure that the monitoring of areas that are not of interest for the intended purpose is limited as much as possible.
• Areas where there is a high level of privacy expectations, such as toilets and other similar locations, are not monitored.
• Exceptionally, in case of duly justified security needs, rooms may be installed in other places, but only after an impact assessment has been carried out and the data protection officer has been informed. In such cases, a specific and visible advertisement will be placed in those places.
• Both employees and customers of S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. they are notified that they are being monitored by video means.
PERSONAL DATA COLLECTED THROUGH VIDEO SURVEILLANCE
• The video system of S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. it is not intended to capture (for example, by selective focusing or orientation) or to process images (for example, indexing, profiling) that reveal “special categories of data”.
• S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. does not intend to use the surveillance system for purposes other than those described.
System description and technical specifications
• Conventionally the video surveillance system is a static system. It has the function of recording images and is equipped with motion sensors. The system can record any movement detected by the cameras installed in the monitored area, along with the date, time and location. All rooms are functional non-stop. When necessary, the quality of the images allows the recognition of those who pass through the area of action of the cameras. For greater security of data processing that can be obtained from video surveillance, the user cannot change the perimeter / purpose of the surveillance. Specially trained operators must respect the privacy settings and access rights.
• There is no interconnection with other systems.
The benefits of the surveillance system
• Increasing control over the development of the game in the escape rooms and preventing possible incidents;
• Restricting the access of foreigners;
• Elimination of losses caused by unforeseen events;
• Compliance with regulations and legislation in force for risky objectives.
PROTECTION OF PRIVACY AND INFORMATION SECURITY
To protect the security of the video system and to increase the degree of protection of life, the following technical and organizational measures have been introduced:
• limiting the storage time of the filmed material, in accordance with the security requirements;
• the storage media (servers on which the recorded images are stored) are located in secure spaces, protected by physical security measures;
• all users with the right of access have signed confidentiality declarations, obliging them to comply with the legal provisions in the field;
• the right of access is granted to users based on the need to know, only for those resources that are strictly necessary for the performance of duties;
• all staff members (both external and internal) sign confidentiality agreements;
• Only the administrator of the company has the right to grant, modify or cancel the right of access of users, according to the general procedure of access to databases. It shall keep an up-to-date list of all persons entitled to access the video surveillance system, specifying the type of access.
ACCESS AND DISCLOSURE OF PERSONAL DATA
Access to stored images and / or the technical architecture of the video surveillance system is limited to a small number of people and is determined by the responsibilities specified in the internal decisions of S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. (for what purpose and what type of access). In particular, S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. imposes limits on the persons entitled to:
• Watch the footage in real time: the images that are played in real time are accessible to those responsible for carrying out the surveillance activity;
• To watch the recording of the filmed material: the viewing of the recorded images will be done in justified cases, such as the cases expressly provided by law and security incidents, by the specially designated persons;
• Copy, download, delete or modify any footage.
• All staff members with access rights receive initial training in the field of data protection. This procedure will be integrated in the training and guidance program, for all users with access rights and responsibilities in the operation of the video surveillance system.
After the training, each participant signs a privacy statement.
Disclosure of personal data
• Any activity of disclosing personal data to third parties will be documented and subjected to a rigorous analysis on the one hand the need for communication, and on the other hand the compatibility between the purpose for which the communication is made and the purpose for which this data was originally collected. for processing (security and access control). Any disclosure situation will be recorded by the system administrator in a Disclosure Record.
• S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. has the obligation to make available to the judicial bodies, at their written request, the video recordings in which the commission of criminal acts is caught.
• The video surveillance system is not used to verify attendance at the program or to evaluate performance at work. In exceptional cases, but subject to the safeguards described above, access may be granted to the Disciplinary Board in a disciplinary investigation, provided that the information helps to investigate a criminal offense or infringement which is likely to prejudice a person’s rights and freedoms.
• Any security breach with respect to video cameras is indicated in the investigation log, and S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L. will be informed of this as soon as possible.
• The storage time of data obtained through the video surveillance system is proportional to the purpose for which the data is processed, so that the images are stored for a period not exceeding 30 days, after which they are deleted by automatic procedure, in the order in which have been registered. In the event of a security incident, the retention time of the relevant footage may exceed the normal limits depending on the time required for further investigation of the security incident. Retention is rigorously documented and the need for retention is reviewed periodically.
• If the storage time exceeds the term provided by this policy, it will be recorded in the Register of records that exceed the storage time, managed by the system administrator.
SC EXTENDED REALITY ESCAPE ROOMS S.R.L. guarantees that it ensures the observance of the rights of the persons concerned, according to the law. All persons involved in the video surveillance activity and those responsible for the management of filmed images, will comply with the Procedure for access to personal data.
• The primary information of data subjects is made clearly and permanently, through an appropriate sign, with sufficient visibility and located in the monitored area, so as to signal the existence of surveillance cameras, but also to communicate essential information on personal data processing.
• The data subjects are warned about the existence of the video surveillance system through the Company’s Internal Regulations, which also includes the purpose of the processing.
Exercise of rights of access, intervention and opposition
• Throughout the period of storage of personal data, the data subjects have the right to access the personal data concerning them, held by S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L., to request the intervention (deletion / update / rectification / anonymization) or to oppose the processing, according to the law.
• Any request to access, rectify, block and / or delete personal data as a result of the use of video cameras should be addressed to S.C. EXTENDED REALITY ESCAPE ROOMS S.R.L.
• The response to the request for access, intervention or opposition is given within 30 calendar days. If this deadline cannot be met, the data subject will be informed of the reason for the postponement of the reply, and will also be informed of the procedure to be followed for resolving the request.
• If there is an express request from the data subject, he / she may be granted the right to view the recorded images concerning him / her or a copy may be sent to him / her. The images provided will be clear, as far as possible, provided that they do not prejudice the rights of third parties (the data subject will only be able to view his own image, without images of other persons that may appear in the record, so that it is not possible to recognize / identify them). . In the case of such a request, the data subject is obliged to identify himself beyond any suspicion (to present the identity document when participating in the viewing), to mention the date, time, location and circumstances in which he was registered by the surveillance cameras. The data subject will also present a recent photo so that designated users can more easily identify it in the filmed images.
• There is the possibility of denying the right of access in case the exceptions provided by law apply. The need to restrict access may also be imposed if there is an obligation to protect the rights and freedoms of third parties, for example if other persons appear in the images and there is no possibility to obtain their consent or they cannot be extracted, by image editing, irrelevant personal data.