Video surveillance privacy information

Identification and contact details of the Data Controller

Data Controller is SERVIZI AZIENDALI PRICEWATERHOUSECOOPERS S.r.l. (“SAPwC” or the “Controller”), with registered office at Piazza Tre Torri n. 2, Milan, jointly with the other Italian legal entities of the PwC Network¹ (the “Joint Controllers”), with which it has executed specific joint control agreements pursuant to article 26 of GDPR, the key content of which is available on demand on the Controller’s premises.

Purposes of the processing of personal data and legal grounds

Your personal data shall be processed solely for the purpose of access control, the protection of movable and immovable property and preserving the safety of individuals. The personal data shall be processed through the following activities: (i) identification of the persons who access the premises of the Controller and possible registration of identification on specific electronic registers and/or IT tools by the personnel in charge, (ii) checking the security of premises and physical spaces through video surveillance.

A video surveillance system is justified by the characteristics of the property where it is installed, which requires surveillance of ample spaces, and by the large number of people accessing the site.

The presence of the video surveillance system is detectable through appropriate signage.

Data processing is necessary to fulfill a legal obligation to which the Joint Controllers are subject (pursuant to Article 6, paragraph 1, letter c, GDPR) relating to the need to protect the health and safety of people in the workplace and it is also based on the Joint Controllers’ legitimate interest (pursuant to Article 6, paragraph 1, letter f, GDPR) in protecting their assets and the safety.

Method of processing and storage of personal data

Processing of your personal data shall take place through the operations listed in Article 4, item 2), of GDPR - whether or not with the help of information systems. In any case, the logic security and physical safety and, in general, the confidentiality of the personal data processed shall be ensured, through all necessary, appropriate technical and organizational measures.

The data collected through the video surveillance system shall be stored for a period of 7 (seven) days. The identification data of the subjects who access the offices, possibly entered in the appropriate electronic register or IT tool, shall be stored for a period of 30 (thirty) days.

An extended length of storage is envisaged only for specific events that justify and make necessary storage for a longer period (e.g.: illicit acts that threaten the security and safety of individuals).

Categories of recipients of the personal data

The data, which shall not be disseminated, may be communicated to the competent judicial authority and shall be processed by the persons tasked with processing expressly authorised by the Joint Controllers for the purposes mentioned above.

Access to the data may also be granted to the entity that maintains the video surveillance system and the entity manning the reception, both acting as data processors.

Rights of the data subject

In accordance with the provisions of Chapter III, Section I, of GDPR, you may exercise the rights listed therein, in particular: right to access (article 15 of GDPR), right to rectification (article 16, GDPR), right to erasure (article 17, GDPR), right to restriction of processing (article 18, GDPR), right to data portability (article 20, GDPR), right to object (article 21 of GDPR), right to lodge a complaint with the supervisory authority, Autorità Garante per la Protezione dei Dati Personali, (Information and contact details on the website www.garanteprivacy.it).

Data subject may send a request to exercise these rights or request further information on the processing of personal data at the following link.

Data Protection Officer

To report any issues concerning personal data processing and to exercise your rights, you may contact the Controller’s Data Protection Officer, whose details are as follows:

Data Protection Officer (“DPO”)

Piazza Tre Torri n. 2, 20145 Milano
PEC (certified electronic mail): dpo-sap@pec-pwc.it
Telephone (02) 66734162

^{[1] Further information on the PwC Network and individual legal entities may be found on www.pwc.com}