Regulation (EU) No 2018/1725 applies to the processing of personal data collected for the purposes of video surveillance.

Parking Solutions Ltd. (Park Aid) may use a video surveillance system in order to protect its users, their property, and other visitors. This video surveillance policy describes the video surveillance system of the committees and the safeguards they take to protect personal data, privacy, and other fundamental rights and legitimate interests of individuals whose personal data have been recorded by cameras.

Who is responsible for processing personal data?

The EESC and the CoR are responsible (in their capacity as data controllers) for the processing of personal data.

What is the purpose of the processing?

Parking Solutions uses its surveillance systems solely for security and access control purposes. The video surveillance system helps control access to the buildings where the parking spaces selected by Park Aid users are located and ensures the security of the buildings, the safety of visitors, and the protection of property and information located or stored there. It complements other physical security systems such as access control systems and systems preventing physical intrusion.

It is part of the measures taken in support of broader security policies and contributes to the prevention, deterrence, and, where necessary, investigation of unauthorized physical access, including unauthorized access to secured premises and protected rooms, IT infrastructure, or operational information. In addition, video surveillance helps prevent, detect, and investigate theft of equipment or assets belonging to the committees, visitors, or staff, as well as threats to the safety of visitors or staff working on site (e.g. fire, physical violence).

The system may not be used for any other purposes. It is not used, for example, to monitor staff performance or attendance. The committees do not use covert surveillance.

What is the legal basis for the processing?

The use of the video surveillance system is necessary for the management and functioning of the committees (Article 5(1)(a) of Regulation (EU) No 2018/1725). It forms part of the general security policies adopted by the committees, and in particular the guidelines governing the work of the Security Service.

The committees’ video surveillance policy was reviewed to align it with the recommendations contained in the Guidelines on Video Surveillance of the European Data Protection Supervisor (EDPS), hereinafter referred to as the “Guidelines”.

What personal data are processed?

Digitally recorded video images.

Who are the recipients or categories of recipients of the personal data?

Internal security staff and external security guards. Video recordings are accessible only to internal security staff. Live video is also accessible to on-duty security guards. The guards work for an external security company.

Access may be granted to the local police if necessary for the purposes of investigating or prosecuting criminal offenses. Images may be provided to police authorities in the context of investigations of crimes or offenses or criminal prosecution. Requests for disclosure must be justified, submitted in writing to the security service, and must comply with the formal and substantive requirements imposed by applicable national legislation.

Where possible and without prejudice to obligations imposed at national level, the committees will require a court order, a written request signed by a sufficiently senior police officer, or a similar official request. The request must specify as precisely as possible why the video recording is required, as well as the exact location, date, and time of the requested footage.

If the police or another national authority of a Member State submits a request for access as part of an official procedure, it must first obtain a waiver of immunity if the recording concerns a member of an EU institution.

In exceptional circumstances, access may also be granted to the following bodies:

• The European Anti-Fraud Office (OLAF) in the context of an OLAF investigation;
• The Ministry of the Interior of the Republic of Bulgaria; or
• Persons carrying out an official internal investigation.

The transfer of data is acceptable if it can reasonably be expected to assist in the investigation or prosecution of a sufficiently serious disciplinary offense or crime.

Are your personal data transferred to a third country (outside the EU) or an international organization?

Your personal data are not transferred to countries outside the EU or to international organizations.

How can you exercise your rights?

You have the right to request access to your personal data. You also have the right to request rectification, erasure, or restriction of the processing of your personal data.

You may submit your requests, which will be processed within 15 working days.

You have the right to lodge a complaint with the European Data Protection Supervisor (edps@edps.europa.eu) if you believe that your rights under Regulation (EU) No 2018/1725 have been infringed as a result of the processing of your personal data by the EESC.

How long are your personal data kept?

Images are retained for a maximum period of 30 days. After that, all images are automatically deleted from the system, which overwrites data older than 30 days. In the absence of a security-related incident, recordings of demonstrators are deleted within 48 hours after the end of the protest.

Are the collected personal data used for automated decision-making, including profiling?

The committees will not use your personal data to make automated decisions about you. “Automated decisions” are defined as decisions made without human intervention. You have the right to object to automated processing at any time and to request that decisions be reviewed by a human.

Will your personal data be further processed for a purpose other than that for which they were collected?

Your personal data will not be further processed for a purpose other than that for which they were collected.

Who can you contact if you have questions or complaints?

If you have additional questions regarding the processing of your personal data, please contact the Park Aid team.