Video surveillance regulations

Video surveillance regulations at VITKOVICE MILMET S.A.

The Regulations define the purpose and the rules of video surveillance functioning at VITKOVICE MILMET S.A., further referred to as MILMET, the locations of system cameras on the premises of MILMET, the rules of registration and recording of information as well as the manner in which it is secured, and also the possibilities of sharing data gathered on events.
The controller of video surveillance devices is VITKOVICE-MILMET S.A. with its seat in Sosnowiec at ul. Grota Roweckiego 130, REGON: 272019626.
The purposes of visual surveillance is to supervise production processes and to ensure safety of property and persons being in the area of MILMET infrastructure in the following locations:
a) The area of the plant in Sosnowiec, at ul. Grota Roweckiego 130,
b) The area of the plant in Siemianowice Śląskie, at ul. Żeromskiego 21.
The basis for implementation of video surveillance system at the Company is art. 6 sec. 1.f) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (general regulation on data protection).
Places under visual surveillance in Sosnowiec at ul. Grota Roweckiego 130:
a) The area along the fence, parking lot, storage areas, production hall of the B2 Department, hall of the B2.1 Department (paint shop).
Places under visual surveillance in Siemianowice Śląskie at
ul. Żeromskiego 21:
a) Roads on the area of the plant, storage areas, area along the fence, parking lot, access gate to the plant, security office, warehouse.
The visual surveillance system functions 24/7
Only the image [vision] from surveillance system cameras is registered and recorded on a physical data carrier.
The visual surveillance system at MILMET consists of:
a) cameras recording events in a resolution that enables identification of persons;
b) device recording and registering image on the physical data carrier;
c) monitors that display the events that are recorded,
The elements of visual surveillance system are upgraded, replaced and extended as required and as financially viable.
The areas subject to visual monitoring are identified with appropriate information signs with a pictogram of security camera.
On the fence at the main gate there are the information boards/signs with the following message:
a) In the location of Sosnowiec:
“Video surveillance
Under surveillance in order to supervise production processes and to ensure safety of property and persons in the area of Companies Infrastructure, covering: buildings (halls, warehouses, security office), areas of parking lots, along the fences, storage areas, access roads, entrance gates. Comprehensive information on the surveillance please are available at 786 949 807 and at (e-mail): rzwierzchowski@vitkovice-milmet.pl”
b) In the location of Siemianowice Śląskie:
“Video surveillance
Under surveillance by VITKOVICE MILMET S.A. in order to supervise production processes and to ensure safety of property and persons in the area of VITKOVICE MILMET S.A. Infrastructure, covering: buildings (halls, warehouses, security office), areas of parking lots, along the fences, storage areas, access roads, entrance gates. Comprehensive information on the surveillance please are available at 786 949 807, at (e-mail): rzwierzchowski@vitkovice-milmet.pl or at the company website: www.vitkovice-milmet.pl”
The recording device and the monitor are located in the premises of MILMET. Additionally, the monitors displaying current image are installed in the security rooms. Access to the visual surveillance image is provided to the employees of a company that provides person and property security services under an agreement concluded with MILMET. Access to the records and images from the video surveillance system is granted only to the authorised employees of MILMET.
Records from the surveillance system may be made available only to authorised authorities to the extent of their legal activities, e.g. to Police, courts of justice, prosecutor's office, at their written request, because making the records available to natural persons may violate the rights and freedoms of other third parties.
The data storage period is up to 30 days, and then the data shall be deleted by overwriting the data in the device that records image. In practice, the period in question may be shorter than 30 days.
In justified cases based on the requests from the above said authorities, in particular when the visual surveillance devices have recorded an event associated with a breach of security of persons and property, the period of data storage may be extended by the time necessary to complete the proceedings concerning the event recorded by the visual surveillance system.
A person interested in securing the data from video surveillance system for the needs of future proceedings may request MILMET, in writing, to secure the data against deletion after the lapse of a standard period for data storage. The request shall be submitted at the Secretariat of the Board at ul. Grota Roweckiego 130, within14 days starting from the day on which the event could have been recorded by the video surveillance system. Requests submitted after this date do not guarantee that the image will be secured as it may have already been removed from the recorder.
A correctly submitted request must include an exact date and place, e.g. production hall, entrance to the parking lot etc. as well as an estimate time of the event. Otherwise, it will not be possible to find the correct image.
There may be slight differences between the real time and the time displayed on the surveillance material because the system is not synchronized with an external source of time.
At a request of the interested party, a person authorised to access the records from the surveillance system at MILMET shall make a copy of a record from the visual surveillance system for a period specified in the request made by the interested party and shall mark it permanently with the following data:
a) consecutive number of the copy;
b) a recorded period;
c) source of data, e.g. CCTV cameras at the production hall;
d) date on which the copy was made;
e) details of a person who made the copy.
The copy shall be stored at the Secretariat of the CEO, in a closed place specially adapted for that purpose.
A copy of the recording will be listed in the register of copies from the visual surveillance system made at a request of an interested person. The register includes the following information:
a) consecutive number of the copy;
b) a recorded period;
c) source of data, e.g. CCTV camera no. .....;
d) date on which the copy was made;
e) details of a person who made the copy;
f) signature of a person who made the copy;
g) information on making the copy available or on destroying it.
A copy created at written request of a person concerned is secured for a period of no more than 4 months and is made available only to authorised institutions, e.g.: Police. If the authorised institutions fail to act for a period of 4 months, the copy will be physically destroyed.
Persons who have access to the image recorded by the video surveillance system are required to comply with the provisions of the law on personal data protection, and their right to access the data requires an explicit authorization by MILMET.
The obligation to provide information to persons whose personal data may be recorded on the surveillance system is fulfilled by way of making the surveillance regulations available via the internet site www.vitkovice-milmet.pl, by phone at: 786 949 807 and in person, at the security office. Majority of persons recorded on the video surveillance system may be impossible to identify by MILMET, and they may be identified only by authorised services, e.g.: by the Police.
Each person shall have the right to object to the processing of data. The objection shall be examined by MILMET.
Each person has the right to request correction of data where it is inaccurate, and - in cases provided for by the law - the right to request the removal or limitation of processing of data. In these cases, the requests should be addressed to MILMET and shall be examined.
Each person has the right to lodge a complaint to a supervisory authority. At present, it is the General Inspector of Personal Data Protection.