Camera surveillance
AVS i Sverige AB is the data controller for the camera surveillance
AVS i Sverige AB is the data controller for camera surveillance. The purpose of camera surveillance is to prevent and detect crime, to contribute to investigation and prosecution and to ensure a safe environment for AVS staff, suppliers and others who are in AVS premises and area. To ensure an appropriate level of security in our warehouses and offices, we use CCTV. The CCTV may process your image and any actions you perform while under CCTV surveillance. The use of CCTV will be indicated by a sign in the warehouse/office.
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1. Purpose of the camera surveillance
In the case of AVS processing of the recorded video material to assist in the investigation and prosecution of criminal offenses, data relating to criminal convictions and offenses involving criminal offenses ("crime data") may be processed when sequences of relevant events are separated from the video material and handed over to the Police. The processing of crime data is, as a general rule, prohibited for non-authorities under Article 10 of the GDPR. However, processing of criminal data may be carried out on the basis of Section 5 of Regulation (2018:219) supplementing the EU General Data Protection Regulation when the processing is necessary for the establishment, exercise or defense of legal claims. Furthermore, it is permitted to disclose material to law enforcement authorities if the data is needed to investigate, prevent, deter or detect crimes that carry a prison sentence. AVS shares criminal data with the Police only when necessary and possible in accordance with the legal conditions described above.
AVS has carried out a balancing of interests in accordance with Article 6(1)(f) of the GDPR and considers that the interests of AVS outweigh the interests or fundamental rights and freedoms of the data subjects that require protection of personal data.
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2. Legitimate interest
AVS has a legitimate interest in preventing, detecting and investigating crime on its premises and grounds. CCTV protects staff, customers, suppliers and property, especially given that AVS handles stolen goods. CCTV has a deterrent effect and reduces the risk of crime, which is necessary to create a safe working environment and avoid financial and reputational losses.
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3. Necessity
CCTV is necessary to prevent and investigate crimes such as burglary, theft and vandalism. CCTV is cost-effective and necessary to achieve security objectives.
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4. Balancing of interests
AVS balances its interest against the interests of the individuals being monitored. Personal data such as video images are sensitive, but camera surveillance is limited to non-privacy sensitive areas and is not used for management purposes. Access to recorded material is strictly limited. CCTV is expected by the public in operations with theft-prone goods and contributes to a better working environment. The ACP considers that their legitimate interest outweighs the interests of the data subjects, taking into account the security measures put in place.
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5. Scope of monitoring
Warehouse and Entrance
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6. Where do we process your data?
Personal data is not transferred to countries outside the EU/EEA.
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7. Measures to strengthen data subjects' rights
Information to data subjects
AVS informs data subjects about the camera surveillance by means of clear signage outside and inside the monitored premises/area and by means of information texts in accordance with Article 13 of the GDPR. Information on the processing of employees' personal data is available internally, while information on the personal data of customers and visitors is available on the AVS website. Those being monitored have the right to request access to recorded material.
Right of access and data portability
Requests for access to personal data are handled according to AVS procedures. A specific assessment is made to determine whether a copy of the personal data can be provided without affecting the rights of others. Alternative means of providing access, such as allowing the data subject to view the material on ACP premises, are always considered. The right to data portability does not apply to CCTV footage where the processing is based on legitimate interest.
Right to rectification and erasure
CCTV footage is considered accurate and therefore cannot be rectified. However, data subjects can supplement the data with a statement. The AVS ensures that personal data is deleted when it is no longer necessary for the purposes for which it is processed. In case of objections to the camera surveillance, an assessment is made as to whether there are compelling reasons to continue the processing; if not, the data is deleted.
Right to object and to restriction of processing
Data subjects have the right to object to camera surveillance based on legitimate interest. The AVS must then demonstrate compelling reasons for the processing that outweigh the interests of the data subject. The right to restriction may apply when the personal data is no longer needed for the purposes of the camera surveillance but is needed to establish, exercise or defend legal claims. Assessments are made on a case-by-case basis with the support of data protection experts.
The Data Protection Authority
The Data Protection Authority (DPA) works to protect all your personal data, such as health and financial information, so that it is handled properly and does not fall into the wrong hands. The IMY handles, among other things, complaints about the mishandling of personal data, notifications of illegal camera surveillance and applications for camera surveillance permits.