Company Video Surveillance Notice

Pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR), and in accordance with the guidance issued by the Italian Data Protection Authority (Provision of 8 April 2010), please be informed that a video surveillance system is installed at the premises and related areas of GAMMA PLASTIC S.R.L., located at Via Visco no. 23 – 35010 Limena (Padua), Italy.

Cameras are installed in both external and internal areas in order to monitor the company’s access points/entrances and internal premises (such as stairwells and emergency exits, corridors, and internal passageways).

The images and recordings collected constitute personal data within the meaning of the applicable laws and regulations, namely any information relating to an identified or identifiable natural person, even indirectly, by reference to any other information, including a personal identification number.

All areas where video surveillance or video recording systems are installed are clearly indicated by appropriate signage containing a short-form privacy notice, as recommended by the Italian Data Protection Authority.

Having stated the above, pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR) and Legislative Decree 196/2003 (Italian Privacy Code), as amended, and as a supplement to the aforementioned short-form notice, we hereby inform you that the collection and processing of images is carried out by our Company in compliance with Article 4 of Law no. 300/1970 (Workers’ Statute), based on an authorization issued by the Territorial Labour Directorate of Padua, and according to the following conditions:

a) Purpose of processing

The system is installed for the protection of company assets, including but not limited to:

  • monitoring company access points and entrances;

  • preventing unauthorized intrusions, theft, criminal acts, and vandalism;

  • ensuring the safety and security of facilities and technical resources, including during periods when personnel are not present on site.

Any purpose related to the remote monitoring of employees is expressly excluded. Any incidental capture of employee images would occur only in an accidental, occasional, and indirect manner.

b) Processing methods

Images are processed using both analog and electronic/IT-based tools and media, in full compliance with applicable laws and in accordance with the principles of lawfulness, fairness, proportionality, and necessity, while ensuring the protection of individuals’ privacy.

c) Authorized personnel

Images will be processed exclusively by company personnel who have been specifically authorized and trained for this purpose.

d) Recipients or categories of recipients of the images

In addition to authorized personnel and/or internal data processors, the images may be disclosed (i.e., made available) to external parties such as law enforcement authorities or other competent authorities upon specific request.
In exceptional and incidental cases, images may also be viewed by personnel of the company responsible for the maintenance of the surveillance system, who are specifically authorized by the data controller to access the system strictly for purposes related to system maintenance and proper functioning, and always in the presence and under the supervision of an authorized company representative.

e) Disclosure of images

Images will not be publicly disclosed under any circumstances.

f) Recording and data retention period

Recorded images stored on recording devices are permanently deleted after the retention period established by the applicable regulations, set at 24 hours, taking into account the particular risk level associated with the activities carried out by the data controller.

Longer retention may occur in exceptional circumstances, such as during public holidays, office closures, or where required in response to specific investigative requests from judicial or law enforcement authorities.

All video-monitored areas are clearly indicated by appropriate signage providing the relevant information.

g) Data subject rights

Data subjects are entitled to all rights set out in Articles 15 to 21 of Regulation (EU) 2016/679, including the right to access their personal data captured through video recordings by submitting a specific request in order to view images relating to themselves. Data subjects may also request the deletion or restriction of data processed in violation of the law, obtain copies of images, or verify possible acts of vandalism affecting property in their possession.

h) Data Controller

The Data Controller is GAMMA PLASTIC S.R.L., represented by its legal representative.

i) Data processors and authorized persons

The legal representative is responsible for responding to data subject requests and may be contacted for any clarification or information.
The company responsible for the maintenance and technical support of the surveillance systems is ELETTROCOS S.r.l.
The individual responsible for the management of the production site is also authorized for the internal management of the surveillance system.

This notice may be supplemented, either orally or in writing, with additional information and details in order to fully meet any informational needs of data subjects regarding privacy matters and to comply with future regulatory developments.