Information on the protection of personal data in matters of video surveillance Actv
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.
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 the controller of the video surveillance systems and equipment installed on board.
HOW WE COLLECT YOUR PERSONAL DATA
ACTV uses a video surveillance system 24 hours a day in the area of offices/depots/stops and in road vehicles and navigation means (boats). Images taken by AVM will be processed with the aid of electronic tools and in compliance with the law on personal data protection and the general provision of 8 April 2010 of the personal data protection supervisor, which does not require prior preventive consent from the data subject.
WHAT PERSONAL DATA CONCERNING YOU MAY BE COLLECTED
The following categories of personal data concerning you may be collected:
- images of natural persons
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 the video surveillance system
The purpose is the security and protection of company assets. 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.
All of your personal data is stored in secure servers and is accessible and usable by our security standards and policies. The recorded images are digitally encoded and stored in encrypted form (in order to make it impossible to view them without a specific program) on the company server; servers are located in rooms with controlled access. 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.
We adopt, among other measures, measures such as:
the strict restriction of access to your personal data, on a need-to-know basis and for the sole purpose communicated, perimeter security systems to prohibit unauthorised access from the outside, the permanent monitoring of access to information systems to detect and stop the abuse of personal data, six-monthly penetration tests aimed at highlighting any leaks in perimeter security.
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 camera are stored for the time specified below:
- on board road vehicles: maximum of 3 days
- in pertaining offices/depots: maximum of 5 days
They are then deleted by using automatic mechanisms (overwriting).
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
Your personal data may be accessed by employees of ACTV, as well as by suppliers and collaborators, duly appointed data processors, who provide support for the provision of services, and by companies in the AVM group (including Actv S.p.A., which carries out the TPL service operationally, and Ve.La. S.p.A. that deals with the marketing of travel tickets and marketing activities), as well as public entities that can access them by law (e.g. judicial authority and public security authority).
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, in particular:
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.
Should you exercise any of the aforementioned rights, it will be our responsibility to verify that you are entitled to do so and, as a rule, we will give you feedback within one 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