Pels Rijcken acts as the data controller with regard to the General Data Protection Regulation (hereinafter: GDPR).
Through this privacy statement, you are informed about the way in which Pels Rijcken processes personal data in the context of camera surveillance in and around the Pels Rijcken office located at Bezuidenhoutseweg 57 in The Hague. This privacy statement should be read in conjunction with our general Privacy Statement, which contains additional information about the processing of personal data, such as with respect to your rights and the sharing of personal data with third parties.
When does this privacy statement apply?
This privacy statement applies to the processing of personal data of passers-by whose images are captured through the use of camera surveillance by Pels Rijcken for the protection of Pels Rijcken’s employees and visitors, as well as to safeguard the goods and information present at Pels Rijcken.
Which (types of) personal data does Pels Rijcken process?
In the context of camera surveillance, the following types of personal data are processed from persons who enter the Pels Rijcken premises or are within the range of the cameras:
- Video footage;
- Date and time of the recording;
- Location of the camera.
The camera surveillance is not aimed at processing special categories of personal data, and the images will not be used to derive or distinguish such personal data. Therefore, special categories of personal data are not processed. Only insofar as the images contain information that gives rise to a suspicion more serious than a reasonable suspicion of guilt, does the processing of camera footage involve the processing of criminal personal data. The legal basis for the processing of criminal personal data is, in that case, Article 33(2)(b) of the UAVG. In the event of suspected unlawful conduct, footage may be shared with authorities, including as part of a report in accordance with Article 161 of the Code of Criminal Procedure (Sv)
The outdoor camera uses a masking technique in the form of a blocking functionality. Applying this functionality ensures the privacy of individuals is protected.
For what purposes does Pels Rijcken use this personal data?
Camera surveillance and the associated processing of personal data serve, among other things, the following purposes:
- Ensuring the safety and well-being of Pels Rijcken’s employees and visitors;
- Protecting Pels Rijcken against burglary, theft, and vandalism;
- Safeguarding goods and information;
- Recording, investigating, and handling (potential) incidents;
- Handling requests, complaints, and disputes;
- Complying with data requests from competent authorities (legal obligations).
- No automated decision-making or profiling, as referred to in Article 22 GDPR, takes place.
On what legal grounds does Pels Rijcken process this personal data?
The processing of personal data in the context of camera surveillance is based on the lawful ground of legitimate interest (Article 6(1)(f) GDPR). It is in the (legitimate) interest of Pels Rijcken and the people who visit Pels Rijcken to process personal data for the purposes described above under “For what purposes do we use this personal data?”. Considering Pels Rijcken's location, the types of legal cases handled, and the threats involved, it is of significant importance for Pels Rijcken to properly protect the building, employees, and visitors. This interest outweighs that of third parties who are filmed.
Disclosure of data at the request of the police or the Public Prosecution Service is based on Article 6(1)(c) GDPR (legal obligation).
How long does Pels Rijcken retain personal data?
Personal data collected through camera surveillance is, in principle, retained for a maximum period of 28 days after which they are automatically destroyed. An exception applies to the camera at the front of the building and the internal corridor to the bicycle storage. For these, a maximum retention period of 5 working days applies, after which the images are automatically destroyed. It may be necessary to retain personal data for a longer period for the settlement of an incident, to comply with a legal, regulatory, or internal policy rule, or as necessary in relation to (the preparation for) legal proceedings or disputes. In such cases, personal data will be retained for longer and deleted as soon as the incident and any resulting legal proceedings or disputes have been resolved.
Who has access to the camera footage?
Access to the camera images is limited to:
- Authorized employees of Pels Rijcken, such as security staff;
- Police or other competent authorities, if legally required or necessary for the investigation of criminal offenses.
How can you exercise your privacy rights?
You have the right to request Pels Rijcken to grant you access to your personal data and/or to correct, supplement, erase, or (have) restrict these. You also have the right to data portability and to object to the processing (see Article 21 GDPR for this). Such a request can be directed to privacy@pelsrijcken.nl.
If you have any questions, comments, or complaints regarding this Privacy Statement, the processing of your personal data, or if you wish to exercise your rights, you can contact us using the contact details below:
Pels Rijcken
Bezuidenhoutseweg 57
2594 AC Den Haag
privacy@pelsrijcken.nl
You can contact the Data Protection Officer of Pels Rijcken by sending an email to privacy@pelsrijcken.nl.
If you believe that your rights have been violated, you can also submit a complaint to the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl).