Information notice regarding video surveillance devices provided
pursuant to EU Regulation 2016/679 and Legislative Decree 196/2003
as amended by Legislative Decree 101/2018
In compliance with the regulations regarding personal data protection, Fasi, in its capacity as Data Controller, pursuant to the provisions of Articles 13 and 14 of EU Regulation 2016/679 wishes t provide you with information regarding:
- the purposes of and methods used in processing your personal data;
- the scope of communication and possible dissemination of the same;
- the nature of the data collected and their provision.
The purpose of this document is to illustrate the nature, purpose and processing methods of the
images captured by devices placed outside and inside the Fasi premises located in Via Vicenza 23 – 00185 Roma.
1- Data Controller
The Data Controller is Fondo Assistenza Sanitaria Integrativa (Fasi) – Via Vicenza 23, 00185 Roma, in the person of its President pro tempore.
2- Data Protection Officer
The Fund has appointed a Data Protection Officer (DPO), who can be contacted by email at dpo@fasi.it.
3- Purpose and legal basis of processing
Processing is performed exclusively for video-surveillance purposes in protection of the company’s assets from unlawful and criminal acts. The legitimising criterion can therefore be found in Art. 6 para. 1 lett. f) of European Regulation 2016/679 (hereinafter also “GDPR”).
4- Data Subjected to processing
The data subjected to processing comprises images from video surveillance devices located both outside and inside the facility and indicated by specific signage.
5- Methods of processing
The processing of images will be carried out using manual, computer, and/or telematic tools, with organizational and processing logics strictly related to the intended purposes, and always in such a way as to ensure the security, integrity, and confidentiality of the data, in compliance with the organizational, physical, and logical measures required by the applicable regulations. This is done to minimize the risks of destruction, loss, modification, unauthorized access, or unauthorized disclosure.
6- Storage period
The images captured by the video surveillance systems are retained for a maximum period of seven days and are then automatically deleted, unless their use is necessary for purposes of protecting the legitimate interest of the Data Controller in legal proceedings.
7- Recipients of personal data and Data Processors
The data provided are not subject to dissemination. Except in cases of proven necessity and by adopting specific authorization and security measures, the images may be transferred to Industria Welfare Salute S.p.A. (IWS), which will process them as an independent data controller. The list of any data processors may be requested directly from the Data Controller.
8- Transfer outside the EU
Your personal data will not be transferred by Fasi to any countries outside the EU. Should any such need arise, this will be done pursuant to Articles 44 et seq. of EU Regulation 679/2016.
9- Rights of the data subject
You may assert your rights under Articles 15 to 22 of the GDPR by contacting the Data Protection Officer via email to dpo@fasi.it
10- Complaints
Furthermore, Fasi informs you that you have the right to make a complaint to the Data Protection Authority according to the procedure described at gpdp.it
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INFORMATION ON WEB SURVEILLANCE DEVICES
Information provided by IWS in accordance with art. 14 of the GDPR
Based on the provisions of paragraph 5.c of the above-mentioned Fasi notice, images from the video surveillance system may be transferred to IWS only and exclusively in the event of incidents involving the assets of IWS itself. IWS will act, to the extent of its responsibility, as an autonomous data controller, based on the legitimate interest (Article 6 paragraph 1 letter f of the GDPR) of protecting the company’s assets.
Any images that may be captured, which will be processed solely by specifically authorised personnel, will not be disseminated or transferred outside the European Union, and will be retained for as long as is strictly necessary for IWS to exercise its right to protect the company assets.
The data subjects may exercise, with IWS, the rights referred to in Articles 15 et seq. of the GDPR by contacting the IWS Data Protection Officer (DPO) by email to dataprotection@industriawelfaresalute.it.