Update on CCTV personal data processing

Aimed at ensuring fair and transparent methods of personal data processing, this notice by our company under the name “SKLAVENITIS CYPRUS LTD”, hereinafter “SKLAVENITIS” is intended to update you on the collection and processing of personal data via CCTV during your presence in its facilities. 
The Controller
The company under the name “SKLAVENITIS CYPRUS LTD”, with registered office at 11 Spirou Kyprianou Street, 4043 Limassol and legally represented.
Purpose & legal basis for processing
The CCTV system, installed at the points we have estimated as high risk for committing illegal actions based on not excessively restricting the privacy of the persons shown therein, only processes image data and not sound data, with the purpose of protecting persons and goods, safety and preventing any illegal actions, protecting life and health and of serving our legal interests in our capacity as Controller, such as the resolution of any disputes or in the context of legal actions. 

Recipients
CCTV data are exclusively processed by specifically authorised and suitably trained persons, who undertake to comply with confidentiality, respect privacy and the basic principles of transparency, safety, trust, legally permissible and necessity.
We do not forward your data to third parties, with the exception of the relevant competent Authorities, exclusively on the basis of our responsibilities as set out by Law or parties who have an expressly defined and actual legal interest, e.g. the victim or perpetrator of an offence, when said data may constitute evidence of the offence.

Record Storage Period
We keep CCTV data for a maximum period of fifteen (15) days, after expiry of which they are deleted. If, during said period, it is deemed necessary to keep a relevant excerpt due to e.g. an incident, illegal action etc., we keep said excerpt for a maximum period of one (1) extra month for the purpose of investigating and defending our legal interest, while, if the incident concerns a third party we keep the relevant excerpt for a maximum period of three (3) extra months.

Rights
As regards the processing of your CCTV data, you have the following rights:

  1. Right to access: you have the right to learn if we process your image and, if so, to receive a copy thereof.
  2. Right to restrict processing: you have the right to ask us to restrict the processing, e.g. not to delete data that you deem necessary for establishing, exercising or supporting legal claims.
  3. Right of opposition: you have the right to oppose the processing.
  4. Right of erasure: you have the right to ask us to delete your data.

If you wish to exercise any of your rights, please contact the Data Protection Officer via email at cy.gdpr@sklavenitis.com , or on tel. No. 25-316816.  To examine a request in relation to image data, you need to define the point and time you were within the range of the cameras and provide your picture, to facilitate us in identifying your data and concealing the data of third parties shown. Alternatively, you can visit our facilities where we can show you the images where you appear. Note that the exercise of the right of opposition or the right of erasure does not imply the immediate deletion of data or the modification of the processing. In any case, we will reply in detail as soon as possible, within the periods specified by the GDPR.

  1. Right to lodge a complaint:

Furthermore, if you deem that the processing of data concerning you is carried out in breach of the legislative framework in force, you have the right to lodge a complaint at the Office of the Commissioner for Personal Data Protection.

The contact information of the Office of the Commissioner for Personal Data Protection is:
1 Iasonos street
1082 Nicosia, Cyprus
Telephone: +357 22 818 456
Fax: +357 22 304565
Email Address: commissioner@dataprotection.gov.cy