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INFORMATION NOTE ON THE PROCESSING OF PERSONAL DATA

Dear visitors and employees of Societe Generale Global Solution Centre S.A. Romania,

We hereby wish to inform you about the processing of your personal data by Societe Generale Global Solution Centre S.A. Romania (“SG GSC Romania”), processing performed in order to ensure the safety of persons, goods and premises of SG GSC Romania.

SG GSC Romania collects and processes your personal data in order to protect your safety, that of employees, as well as the safety of the goods and premises of SG GSC Romania. The processing of your personal data is carried out as a result of the legitimate interest of the company to ensure a secure working environment that allows SG GSC Romania to guarantee the safety of its own staff and goods, necessity derived also from the obligation to comply with Law no. 53/2003 – Labor Code, Law no. 319/2006 on safety and health at work, Law no. 333/2003 regarding the protection of objectives, goods, values and protection of persons.

Thus, we specify below which are the categories of personal data processed, the purposes for which personal data are collected and processed, the recipients of these data, the rights you benefit from.

CATEGORIES OF PERSONAL DATA COLLECTED AND PROCESSED

In order to ensure the safety of persons, goods and spaces of SG GSC Romania, as well as to achieve the legitimate interests of SG GSC Romania or to comply with legal obligations, SG GSC Romania will process:

  • your image from video and / or audio recordings, based on the legitimate interest of SG GSC Romania. Thus, SG GSC Romania implemented the video monitoring system by installing CCTVs next to the access roads in the company’s premises, as well as in the common areas through which the access of visitors / employees / collaborators and third parties to these premises is monitored, in order to ensure the security of SG GSC Romania’s persons, goods, premises and information, this processing being performed based on the legitimate interest of SG GSC Romania. The personal data represented by your image, collected and processed through this video monitoring system, are stored for a maximum period of 30 days from the date the image was captured.

PURPOSES OF PROCESSING

SC GSC Romania processes your image for the following purposes:

  • to ensure the security of SG GSC Romania’s persons, premises and goods. As a result of such monitoring, your image will be captured every time you cross the surveillance camera’s field of view. The images collected through the CCTV system will be processed for a maximum period of 30 days from the date of capture and will be accessed only by small number of authorized personnel.
  • to monitor the access to SG GSC Romania’s premises and IT systems;
  • to prevent and investigate fraud/ destruction/ fire cases
  • to protect SG GSC Romania and you from harm, theft, fraud, abuse or other misconduct by processing the video recordings captured by the CCTV system.

LEGAL BASIS OF PROCESSING

For the purposes indicated above SG GSC Romania will process your image based on its legitimate interest in ensuring the security of its personnel, data and information processed or of the goods and premises in its use or property, as described above.

Where the legitimate interest of SG GSC Romania or  the legal provisions at national, European or international level does not constitute a basis for the processing of data, and the processing of your data is requested by SG SGC Romania in order to fulfill certain purposes,  after your prior information in accordance with the applicable legal provisions, your consent will be required and collected as per the provisions of EU Regulation 679/2016 (GDPR). In such situations, your consent will represent the legal basis for the data processing.

When your personal data are processed under your consent, you can withdraw this consent at any time, in accordance with the provisions of EU Regulation 679/2016 (GDPR) and Law 190/2018, by submitting a request in this respect to the Data Protection Officer at the email address indicated in this information. The personal data processing operations based on your consent will be notified to you and your consent will be expressly requested.

DATA RECIPIENTS

SG GSC Romania values the privacy of its visitors, employees and collaborators. For this reason, your personal data will be transferred to third party service providers involved in the video monitoring process for installation, storage and maintenance purposes, to ensure your security and the achievement of SG GSC Romania’s legitimate interests as these interests derive from the purposes illustrated above.

Therefore, the categories of recipients of your personal data are the following:

  • specialized departments within SG GSC Romania, such as the Internal Control Department / Physical Security / IT / HR;
  • Global Technical Services SA as service provider for physical security equipment installation, virtual machine hosting in relation to the data collected for the purpose of physical security and software maintenance for monitoring access to SG GSC Romania premises;
  • central / local public authorities – may have access to the data collected if they are requested within control or investigation activities, in accordance with the legal provisions in force.

DATA TRANSFER

Considering that the servers of GTS Technical Services SA (the provider of physical security equipment installation services, virtual machine hosting in relation to the data collected for physical security purposes and software maintenance for access monitoring in SG GSC Romania’s premises) are located in Romania, your data will not be transferred outside the EU.

RIGHTS YOU BENEFIT FROM

As visitors / employees / collaborators of SG GSC Romania and data subjects in accordance with the provisions of EU Regulation 679/2016 “GDPR” you benefit from the following rights regarding your personal data:

  1. Right to data access

As a data subject you have the right to request and obtain from SG GSC Romania a confirmation of the fact that your data are or are not processed by SG GSC Romania and, if so, you have the right to access those data, as well as to information such as: the purposes of processing, the categories of data processed, the recipients or categories of recipients of the data, the retention period of the data thus processed. Also, to the extent that SG GSC Romania has obtained your personal data from other sources and not from you directly, you may request any available information regarding the source of the data thus collected.

  1. Right to rectification

As data subject, you have the right to obtain from SG GSC Romania the rectification and / or completion of inaccurate and / or incomplete personal data concerning you.

  1. Right to data deletion (“Right to be forgotten”)

As a data subject, you have the right to obtain from SG GSC Romania the deletion of personal data concerning you, and SG GSC Romania has the obligation to delete personal data without undue delay if one of the following reasons applies:

  1. personal data are no longer necessary for the purposes for which they were collected or processed;
  2. you withdraw your consent based on which the processing takes place, where the basis for the processing of the data is represented by your consent;
  3. you exercise your right to opposition;
  4. the personal data has been illegally processed;
  5. the personal data must be deleted in order to comply with a legal obligation of SG GSC Romania under Union or national law;
  6. the personal data were collected in connection with the provision of information society services.

SG GSC Romania’s obligation to delete your personal data will not apply to the extent that the processing is necessary:

(a) for the exercise of the right to free expression and information:

(b) for compliance with a legal obligation which provides for processing under Union or national law;

(c) for establishing, exercising or defending a right in front of a court.

  1. Right to restriction of processing

As data subject you have the right to request and to obtain from SG GSC Romania the restriction of processing of the data belonging to you in case one of the following applies :

  • you challenge the accuracy of the data, for a period that allows SG GSC Romania to verify the accuracy of the data;
  • the processing is illegal and you object to the deletion of personal data, requesting in return the restriction of their use;
  • SG GSC Romania no longer needs personal data for the purpose of processing, but you request them for the establishment, exercise or defense of a right in front of a court; or
  • you have objected to the processing of data for the period of time in which it is verified whether the legitimate rights of SG GSC Romania prevail over those invoked by you.
  1. Right to data portability

As data subject you have the right to receive the personal data concerning you and which you have provided to SG GSC Romania in a structured, commonly used and machine-readable format (e.g. through an online form), and you have the right to transmit this data to another operator, without obstacles from SG GSC Romania, if:

(a)  the processing is based on consent; and

(b) the processing is performed by automatic means.

  1. Right to opposition

You may object at any time, for reasons related to your particular situation, to the processing carried out on the basis of the public interest or the legitimate interest pursued by SG GSC Romania or by a third party. SG GSC Romania will no longer process personal data belonging to you as a result of the exercise of this right by you, unless SG GSC Romania has legitimate and compelling reasons justifying the processing or when the purpose of further processing of data is represented by the establishment, exercise or defense of a right in front of court by SG GSC Romania.

You can also contact the National Supervisory Authority for Personal Data Processing (ANSPDCP) at 28-30 G-ral Gheorghe Magheru Bld., District 1, post code 010336, Bucharest, Romania; www.dataprotection.ro

If you wish to exercise any of the rights set forth above, please contact the Data Protection Officer at ana-maria.stefan@socgen.com

DATA RETENTION PERIOD

The personal data collected by SG GSC Romania about you using video surveillance means will be stored by SG GSC Romania for a period of 30 days from the date of their capture. Thus, SG GSC Romania will no longer store these categories of data after the expiration of the 30-day period from the date of their capture by video-CCTV monitoring systems.

TECHNICAL AND ORGANIZATIONAL MEASURES FOR DATA SECURITY

SG GSC applies technical and organizational measures to ensure the security of your data. These measures include:

  1. Limited access to information based on the need to know, need to see and need to have principle;
  2. Each process / application / program will access only that information necessary to achieve a legitimate purpose or interest;
  3. Multiple filters to ensure security and security control;
  4. Procedures for ensuring and strengthening security standards in each location;
  5. Efficient security systems in order to prevent and react in case of a security incident;
  6. Periodic training of employees and collaborators with access to data regarding the obligations regarding the protection of personal data etc.

 

CONTACT DETAILS OF DATA PROTECTION OFFICER

ana-maria.stefan@socgen.com 

West Gate, 24 Preciziei Street, H4 Building, 4th floor, District 6, Bucharest.