Level 2 Update for the processing of personal data through a video surveillance system

1. Controller:

The company with the name “Eurocatering BG”, based at  117 Batareya str., 1839 Sofia, tel.+359 898 250 265,  [email protected] is the Data Controller of the subjects, whose personal image data is collected by the CCTV systems installed on the Company’s premises.

Data Protection Officer contact details:

e-mail: [email protected]

contact phone: +359 898 250 265

The Company has installed and operated a Video Surveillance System at the following locations:

2. Purpose of processing and legal basis:

“Eurocatering BG”, uses a surveillance system for the following legal and defined processing purposes according to the groups of cameras that are installed in the premises of the Company’s facilities for the purpose of Food safety, ensuring Health and Safety at work, as well as the in general protection of Persons and Goods in its facilities:

A) at the entrances / exits of its facilities, with cameras focused on them, for the supervision and prevention of illegal entry, for the protection of its employees as well as the visitors and partners of “Eurocatering BG” as well as for the protection of assets from theft, arson or other illegal action

B) in specific areas within the facilities of “Eurocatering SA” which are judged to need special protection, without being focused on the persons of the data subjects.

The processing is necessary for the purposes of legitimate interests pursued by us as the Controller (Article 6 para. 1f GDPR) for the protection of persons and goods on our premises, which has been fairly weighed against your privacy, without prejudice to fundamental rights and your freedoms.

3. Analysis of legitimate interests

The processing of image data through video surveillance systems in the context of the above purposes, which meet the guarantees of the law for their placement, is based on the legitimate interest of “Eurocatering SA” to protect and ensure the safety of life, physical integrity, as well as of the property of the persons who are legally present in the monitored areas of the Company’s facilities, whether they are employed by “Eurocatering BG” or are customers or visitors to its offices from dangerous attacks against life.

The same applies to the protection of the space, the goods as well as the customers of “Eurocatering SA” who are inside it from illegal acts, such as theft.

We only collect and process your personal image and video data and limit their download to places that we have assessed as having an increased likelihood of committing illegal acts without focusing on places where the privacy of the people whose image is taken may be unduly restricted, including their right to the respect of personal data. The cameras do not pick up sound and there is no optical focus. The system in question has only been installed in specific areas related to the protection of Persons and Goods, where it is absolutely necessary to take measures to protect them. Of course, neither are image data collected from spaces in which data subjects have heightened expectations for their privacy (e.g. restrooms and lobbies). Regarding the use of the CCTV video surveillance system, an Impact Assessment has been prepared in accordance with Article 35 GDPR taking into account the nature, scope, context and purposes of the processing of the personal image data of the data subjects, which is available to you after the submission of your application to the details of the Data Protection Officer of “Eurocatering BG”, which are available above.

4. Security of our company’s systems

Our company implements appropriate technical and organizational measures and strict security procedures to protect your personal image and video data that it collects and processes from unauthorized disclosure, use, conversion or destruction.

5. Recipients

The recorders with the cameras of the video surveillance system are connected to a network, which is protected from unauthorized access by using passwords. Access to the video surveillance system and the personal data it collects, including real-time images and recorded material, is limited to a small number of designated individuals, according to specialized job roles and using special protocols.