Video Surveillance Policy at INA, Plc.

VIDEO SURVEILLANCE IN GENERAL

INA, Plc. uses video surveillance systems in the facilities/premises at the locations of INA, Plc. throughout the Republic of Croatia with the aim of protecting the facilities and other assets owned by INA, Plc. and persons: employees, other staff, suppliers, business partners, customers and visitors, as well as all others persons arriving to, moving about and using the abovementioned assets at the locations of INA, Plc.
 
INA, Plc. may use video surveillance recordings for the purpose of reconstructing and investigating security incidents, malfunctions, potential hazards or unauthorised access to the protected areas.
 
INA, Plc. is the controller of data processing by means of video surveillance and, in this regard, it processes personal data by creating recordings that make up the storage system. Video surveillance primarily refers to work processes, but subordinately, it refers to the behaviour of the persons entering the field of view of a surveillance camera.  

PURPOSE AND LEGAL BASIS

Processing of personal data by means of video surveillance is based on the applicable regulations governing financial operations (Act on Protection of Monetary Institutions) and the legitimate interest for the purpose of controlling entry to and exit from INA, Plc. locations and reducing the exposure of the persons to the risk of robbery, burglary, violence, theft, work-related irregularities and similar occurrences if the analysis has shown that the legal, economic and other interests of the data controller prevail over the interests of data subjects.
 
Processing of personal data by means of video surveillance is carried out in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, the Act on Implementation of the General Data Protection Regulation and other applicable regulations regulating the subject matter, and internal documents of INA, Plc. Each video surveillance system is designed and installed in accordance with the provisions of the Private Protection Act, the Occupational Health and Safety Act and the Regulation on the Conditions and Methods of Implementing Technical Security Measures.
 
Partners of INA, Plc. who are part of the COCA retail business model (Company Owned Commission Agent operated) or who otherwise possess and use the facilities of INA, Plc. must inform their employees about the collection of their personal data by means of video surveillance at a particular location. They must also adhere to the applicable regulations governing the processing and protection of personal data and take actions to prevent any misuse of such personal information.

INFORMING 

In all facilities or premises of INA, Plc. where video surveillance has been set up, a special notice must be displayed at the entrance into the perimeter of the area under surveillance, which must contain a symbol or an image of the video surveillance camera and the following information in Croatian and English:
 
Videonadzor na ovoj lokaciji provodi se neprekidno, a videozapisi se obrađuju temeljem legitimnog interesa u svrhu zaštite osoba i imovine te poštivanja zakonskih obveza INA, d.d. kao voditelja obrade. Osobni podaci obrađeni videonadzorom na ovoj lokaciji poslovna su tajna i čuvaju se, u pravilu, najdulje 180 dana. Uvid u osobne podatke obrađene videonadzorom može biti omogućen tijelima javne vlasti. Više informacija u vezi s obradom osobnih podataka možete pronaći u Politici zaštite osobnih podataka u Ini, Plc. objavljenoj na stranici www.ina.hr, a svoja prava u vezi s obradom osobnih podataka videonadzorom možete ostvariti putem sljedećeg kontakta:
 
INA, d.d.
Avenija Većeslava Holjevca 10
10000 Zagreb
Tel.: 0800 11 12 (besplatni telefon)
e-mail: szop@ina.hr
 

The wording in the English language:

This area is under constant video surveillance and video recordings are being processed on the basis of legitimate interest for the purpose of protection of persons and property and fulfilment of legal obligations of INA, Plc. as Data Controller. The personal data collected by means of video surveillance at this location are a business secret, and they are, as a rule, kept up to 180 days. Insight into the personal data processed by means of video surveillance can be provided to public authorities. More information about the processing of personal data can be found in the Privacy Policy published on www.ina.hr. Your rights relating to personal data processed by means of video surveillance may be exercised using the contact below:

INA, d.d.
Avenija Većeslava Holjevca 10
10000 Zagreb
Tel.: 0800 11 12 (toll free number)
e-mail: szop@ina.hr

A notice that the area is under video surveillance must be displayed before or at the entrance into the perimeter of the area under surveillance. Upon entry into the perimeter or the facility/area under video surveillance, all persons shall be deemed to have been informed about the processing of their personal data by INA, Plc.

DATA PROTECTION AND RIGHT OF ACCESS

Video surveillance equipment (cameras, recorders, routers) is part of the INA, Plc. business network, but it is configured in a separate, virtually partitioned network segment (VLAN) that is maximally physically and logically protected.  
 
Access to and management of video surveillance devices at INA, Plc. is handled by employees of the organisational unit in charge of corporate security.
 
Employees of the organisational unit in charge of corporate security may assign the right of access to video surveillance equipment to employees of the contractual security services provider and to managers and workers at individual locations where the video surveillance is set up, i.e. to the organisational unit in charge of maintenance, for the purpose of performing their duties. Each access is carefully recorded in the system for recording access to video surveillance recordings, which notes the time and place of access, as well as the identification of the person who accessed the data.
All video recordings must be clearly identified (marked) by date, time and place of origin, including a unique way of marking individual cameras.

Video recordings on video recorders and/or storage devices are not permanently archived, but they are typically stored for up to 180 days, depending on the capacity of the recorder or the data storage unit, after which they are automatically deleted. In case data records have to be kept for the purposes of court, administrative, arbitration or other equivalent proceedings after the 180-day period has expired, they will be kept in the organisational unit in charge of corporate security until the proceedings are completed. All video recordings are property of INA, Plc. and constitute a business secret.
 
INA, Plc. will not submit video recordings or make them available to unauthorised persons in any way and in any form.
 
INA, Plc. keeps a database of video surveillance recordings and has an established record of the processing activities for this database and a competent data protection officer.

SURVEILLANCE CENTRE 

All video surveillance security cameras and recorders must be connected to INA, Plc. Surveillance Centre. 24-hour video surveillance monitoring is performed by the contractual security company with which INA, Plc. has concluded a relevant contract containing all the necessary elements of personal data processing.

RIGHT TO INFORMATION AND RIGHT TO VIEW RECORDINGS 

Video surveillance recordings may be provided to the public authorities, court and/or other competent authorities for the purpose of performing activities falling within the scope of their competence. Data subjects have the right to be informed about the processing of their personal data by means of video surveillance, and at their elaborated written request, individual recordings may be found and viewed.
 
In the case of personal data processing by means of video surveillance based on legitimate interests for the purpose of protecting the persons and property, the data subjects shall not be entitled to the right to be forgotten within a period of 180 days, which is the maximum time a video recording may be retained, or longer in case of court, administrative, arbitration or other equivalent proceedings.

PROCEDURE IN CASE OF MISUSE

In case of a personal data breach, the competent responsible person / manager or the competent data protection officer at INA, Plc. shall, without undue delay, act in accordance with the applicable regulations, while fully respecting the privacy rights of data subjects.

EXERCISE OF DATA SUBJECTS’ RIGHTS

Data subjects may exercise their rights relating to the processing of their personal data by means of video surveillance using the contact below:
 
INA, d.d.
Avenija Većeslava Holjevca 10
10000 Zagreb
Tel.: 0800 11 12 (toll free number)
e-mail: szop@ina.hr
 
Additional information about the protection and processing of personal data at INA, Plc. can be found in the Privacy Policy, which is publicly available at the following link: https://www.ina.hr/privacy-policy.
Choose language