Video surveillance privacy information
Privacy notice pursuant to articles 13 and 14, GDPR
Identification and contact details of the Data Controller
Data Controller is SERVIZI AZIENDALI PRICEWATERHOUSECOOPERS S.r.l. (“SAPwC” or the “Controller”), with registered office at Piazza Tre Torri 2, Milan, jointly with the other Italian legal entities of the PwC Network1 (the “Joint Controllers”) at whose premises or offices the data subject attends, with which it has executed specific joint control agreements pursuant to article 26 of GDPR.
The key content of this agreement is available on demand on the Controller’s premises.
Purposes of the processing of personal data and legal grounds
Personal data shall be processed solely for the purpose of access control, the protection of movable and immovable property and preserving the safety of individuals. The personal data shall be processed through the following activities: (i) identification of the persons who access the premises of the Joint Controller and registration of identification in dedicated electronic registers and/or IT systems by authorized personnel, (ii) checking the security of premises and physical spaces through video surveillance.
A video surveillance system, where applicable, is justified by the characteristics of the property where it is installed, which requires surveillance of ample spaces, and by the large number of people accessing the site.
The presence of the video surveillance system can be identified through appropriate signage.
The processing is necessary in order to comply with a legal obligation to which the Joint Controllers are subject, pursuant to Article 6(1)(c) of the GDPR, in relation to the need to protect the health and safety of individuals in the workplace, and is also based on the legitimate interest of the Joint Controllers, pursuant to Article 6(1)(f) of the GDPR, in protecting their corporate assets.
Method of processing and storage of personal data
Processing of the personal data shall take place through the operations listed in Article 4, item 2), of GDPR - whether or not with the help of information systems. In any case, the logic security and physical safety and, in general, the confidentiality of the personal data processed shall be ensured, through all necessary, appropriate technical and organizational measures.
Personal data collected through the video surveillance system will be retained for a period of 7 (seven) days. Identification data relating to individuals accessing the site, where such data are recorded in the relevant electronic registers and/or IT systems, will be retained for a period of 30 (thirty) days.
An extended length of storage is envisaged only for specific events that justify and make necessary storage for a longer period (e.g.: illicit acts that threaten the security and safety of individuals).
Categories of recipients of the personal data
Personal data, which shall not be disseminated, may be communicated to the competent judicial authority and shall be processed by the persons tasked with processing expressly authorised by the Joint Controllers for the purposes mentioned above. Access to the data may also be granted to the entity that maintains the video surveillance system and the entity manning the reception, both acting as data processors.
Rights of the data subject
In accordance with the provisions of Chapter III, Section I, of GDPR, you may exercise the rights listed therein, in particular: right to access (article 15 of GDPR), right to rectification (article 16, GDPR), right to erasure (article 17, GDPR), right to restriction of processing (article 18, GDPR), right to data portability (article 20, GDPR), right to object (article 21 of GDPR), right to lodge a complaint with the supervisory authority, Autorità Garante per la Protezione dei Dati Personali, (Information and contact details can be found on the authority’s website www.garanteprivacy.it).
You may request to exercise such rights or request further information on the processing of your personal data (fill the form and send a request).
Data Protection Officer
Office of Data Protection Officer (“DPO”)
Piazza Tre Torri, 2 – 20145 Milano PEC: dpo-sap@pec-pwc.it
Telephone +39 02 66734162
Notes
(1) The Italian legal entities of the PwC Network are as follows:
PricewaterhouseCoopers S.p.A.
PricewaterhouseCoopers Business Services S.r.l.
PwC Tax Società tra Professionisti a Responsabilità limitata
PwC Legal Società Tra Avvocati a Responsabilità limitata
PricewaterhouseCoopers Advisory S.p.A.
PricewaterhouseCoopers Services S.r.l.
PwC Tax & Legal Studio Professionale Associato
PwC Italia S.r.l.
Fondazione PwC Italia Ente del Terzo Settore
Servizi Aziendali PricewaterhouseCoopers S.r.l.
Further information on the PwC Network and individual legal entities may be found on www.pwc.com (visit the website)
