Article 1 – Introduction
The Tramhuis Foundation is located in the heart of Rotterdam. CCTV footage is recorded in and around the Tramhuis for security purposes to ensure the safety of visitors, employees, and property.
Article 2 – Purpose
This protocol describes the practical implementation of camera surveillance at the Tramhuis. It explains how Tramhuis handles the recording, collection, and storage of personally identifiable data from security camera recordings.
This takes into account, on the one hand, the need for camera recordings to protect employees and clients from aggression, and to properly secure property, infrastructure, and business processes against theft, fraud, or other forms of unauthorized access. On the other hand, the privacy of employees and visitors is safeguarded.
Article 3 – Target group
This protocol applies to employees, visitors and relations who are present at the Tramhuis location.
Article 4 – General principle
The recordings will be used exclusively for the purposes described in this protocol, namely access control, protection, and security of employees, third parties, and property. The images will explicitly not be used for tracking or monitoring employees. Recorded images will only be retrieved after an incident has occurred.
Article 5 – Tasks and responsibilities
- The camera surveillance is carried out under the responsibility of the Tramhuis Foundation.
- The Tramhuis Foundation ensures that the images are handled with care and in accordance with applicable legal provisions. This protocol is an elaboration of that process.
- The Tramhuis Foundation immediately secures images, if they have not yet been deleted in accordance with Article 9, when an incident has occurred and/or when a request is made by a data subject or a third party (including the police or visitors).
- The technical management and maintenance of the camera system, as well as the storage of images, is carried out on-site by Stichting Tramhuis.
- The camera footage may only be viewed by authorized employees, namely the management of the Tramhuis Foundation and the building manager. Management may delegate this authority to employees in daily management, IT, privacy, or HR. They are authorized to assess the suitability of the footage for the purposes of making it available to data subjects or making it available to third parties as referred to in Articles 7 and 8.
- Authorized employees have signed an integrity and confidentiality statement. This statement is included in the personnel file.
Article 6 – Privacy of employees and third parties
The camera surveillance is compatible with the purpose of security and surveillance. The footage will be used exclusively for the purposes described in Article 2.
Article 7 – Access to recorded images
In view of the protection of privacy, the following restrictions apply to the right of access:
- Those involved can request images from the Tramhuis Foundation.
- In principle, a person only has the right to view images in which he or she can be seen.
- When requesting access, the data subject must indicate the time and duration of the desired images (for example, between 9 p.m. and 9:15 p.m.).
- The footage will be viewed at a location determined by the Tramhuis, in the presence of an authorized employee. The person involved must report to the Tramhuis in person to verify their identity and present valid identification.
Article 8 – Providing images to third parties
- Images will only be provided to third parties if this is compatible with the purpose of collecting the images.
- Imagery will be provided to the police if the police explicitly request it, referring to the statutory provision on which it is based (written request, or if this is necessary for the performance of their public-law duties).
- The authorized employee pursuant to Article 5 requests the privacy officer to assess the legitimacy of a request for disclosure in writing. This is done in accordance with the provisions of the General Data Protection Regulation.
Article 9 – Retention period and system management
- CCTV surveillance is provided through a closed system. Footage is stored on-site.
- The images are automatically deleted after fourteen (14) days. This period is sufficient to be able to retrieve the images in the event of any incidents.
- If an incident is recorded on camera footage, the recording will be retained until the incident has been resolved. Authorized officials may then access the footage based on their authority.
Article 10 – Complaints
If a data subject has a complaint about the camera surveillance or the handling of requests for access, he or she can submit a complaint via info@tramhuis.nl , which will process the complaint.