Information on the protection of personal data in matters of data collected by vedr systems
The Company ACTV S.p.A. (hereinafter ACTV or the Company), which is subject to the management and coordination of the Azienda Veneziana della Mobilità spa (hereinafter AVM), is, therefore, part of the AVM Group, together with Ve.La. s.p.a., and carries out the operational execution of the urban public transport services entrusted to AVM, as well as the local public transport services in the Municipalities of Venice and Spinea, directly entrusted to it by the Government until the final award of the current bankruptcy proceedings.
Given that the services are integrated, the corresponding tickets, which are issued by the parent company, AVM are as well. ACTV is the processing controller of the personal data collected for the local public transport service entrusted to it directly by the Government Body, as well as owner of such means.
HOW WE COLLECT YOUR PERSONAL DATA
ACTV collects and processes your personal data through a system called V.E.D.R. ("Video Event Data Recorder"), which consists of a control unit (Octo Box LDT) and 2 or 3 internal cameras installed on board buses and trams, with the possibility of capturing video on the front and inside the vehicle itself, so that data relating to the position, acceleration, vehicle speed and images can be acquired automatically when special events occur that produce accelerations above a certain threshold, in particular when accidents occur. The same data can also be acquired by activating the devices manually. The Data Protection Supervisor has already expressed the lawfulness of the system described above with measures n°. 2012 of 29/11/12, and n°. 78 of 25/02/16.
WHAT PERSONAL DATA CONCERNING YOU MAY BE COLLECTED
The following categories of personal data may be collected:
- Images, as well as identification data concerning the means of transport.
FOR WHAT PURPOSES YOUR PERSONAL DATA MAY BE USED
The processing of personal data by European data protection legislation must be subject to one of the various legal requirements, and we are obliged to indicate these requirements for each processing operation described, as you can read below:
a) Management of V.E.D.R. (Octobox)
The purpose of the system is to provide support in the kinematic reconstruction of claims involving vehicles owned by ACTV and therefore to safeguard the company’s assets from fraudulent behaviour by third parties or staff, as well as indirectly increase the safety of users and employees. The legal ground is the pursuit of the controller’s legitimate interest.
HOW WE KEEP YOUR PERSONAL DATA SAFE
ACTV uses a wide range of security measures to improve the protection and maintenance of the security, integrity and accessibility of your personal data.
Our suppliers, identified as personal data processors pursuant to Article 28 of EU Regulation 679/16, undertake to ensure physical, electronic and procedural safeguards aimed at protecting your personal data in compliance with the law and the utmost accountability.
All your personal data is stored on secure servers and is accessed and used according to our standards and our security policies (or equivalent standards for our suppliers or business partners).
In order to view the images a special protected computer station needs to be accessed. The computer stations dedicated to processing the images in question are not connected to the corporate intranet or to other computer stations.
The computerised system that manages the video surveillance equipment is provided with electronic authentication keys (password system), differentiated according to the operational management profile to which the user is enabled; it also keeps a record of all accesses and the ID/profile used.
HOW LONG WE RETAIN YOUR INFORMATION
We store your personal data only for the time necessary to achieve the purposes for which it was collected or for any other legitimate purpose related to it.
The images captured on the system installed within each vehicle are recorded and stored for a maximum of 2 years, in relation to the term within which any claim related to damage caused by vehicles can be made as set forth in Article 2947, paragraph 2, of the Italian Civil Code. They are then deleted by using automatic mechanisms.
Should we need to defend ourselves or take action or even make claims against you or third parties, we may retain the personal data we deem necessary to process for such purposes, for the time that such claim can be prosecuted.
WITH WHOM WE MAY SHARE YOUR PERSONAL INFORMATION
The images taken can be viewed only by the insurance company UnipolSai Assicurazioni S.p.A. (independent controller) and the processor (Octocam S.r.l.), who have been specifically identified in writing by the Company.
Moreover, should any event occur to the detriment of the company or the employees thereof, or following a specific investigative request, the data may be communicated to the judicial authorities or to the police forces. Depending on the request, the images can only be viewed at the Company’s facilities or copied and exported on typical computer media (CD, DVD) and delivered to the competent authorities.
If you have any questions regarding our processing of your personal data, please use the web form "privacy" in the "contacts" section of the site ww.avmspa.it or contact the telephone number 0412722111, asking the secretariat of the Legal and Corporate Affairs.
We would also like to inform you that the Company has appointed an external data protection officer (DPO), whose contact details are firstname.lastname@example.org, to whom you may apply in general for matters relating to the protection of personal data and related rights.
YOUR DATA PROTECTION RIGHTS AND YOUR RIGHT TO LODGE COMPLAINTS WITH THE SUPERVISORY AUTHORITY
You have the right to ask us, under the legal conditions:
- access to your personal data
- the deletion of any data for which we no longer have any legal basis for processing
- the limitation of the way in which we process your personal data, in the cases provided for by law.
In the event that you exercise any of the aforementioned rights, it will be our responsibility to verify that you are entitled to exercise it and we will give you feedback as a rule within a month.
If you are not satisfied with the way in which we process your personal data or with our feedback, you have the right to lodge a complaint with the supervisory authority, the contact details of which can be found on the website www.garanteprivacy.it