CCTV Installation and Operation Policy

The CCTV system was installed for the protection of individuals and property. The company operates equipment of particularly high value, which is essential for the smooth daily operation of the business. The need to protect this equipment and to deter illegal acts by third parties justify its surveillance through a closed-circuit television system.

Additionally, the company receives many visitors daily for goods delivery and service provision. Given the conditions of the business location, installing the CCTV system was necessary to ensure the safety of our employees and company property.

The company under the name “PEARL M.A.E.” acts as the Data Controller for the personal data collected through the video surveillance systems installed on the company’s premises.

The use of video surveillance systems is carried out to protect individuals (e.g., employees, visitors), property, and the company’s facilities from unlawful acts such as theft, damage, or other violations.
The processing is based on the company’s legitimate interest according to Article 6(1)(f) of the GDPR.

For the purpose of informing both employees and customers, warning signs regarding the use of a surveillance system have already been placed in clearly visible locations within the business, in accordance with the standard set by the Hellenic Data Protection Authority (HDPA) in Directive No. 1/2011 and the HDPA press release with protocol number G/EX/3921/09.06.2020. Additionally, a detailed second-level notice, which meets the relevant requirement, is provided through this text, published on the company’s website.

Camera Locations – Audio Recording

A total of two (2) cameras are installed in the company:

• On the third floor, in the lobby of the main entrance, a camera captures footage of the area around the company’s entrance door for the purpose of monitoring access, as well as part of the external corridor.
• On the third floor in the Computer/Data Room, capturing footage of critical systems.

The installed cameras do not record audio.

Data Recipients

Access to the footage is restricted to authorized company personnel appointed by management for this purpose.
The footage is not shared with third parties, except in cases of incidents, where the data may be shared as follows:

• With competent police and/or prosecutorial and/or judicial authorities upon legal request.
• With a natural person (image/video extract that depicts them / right of access).
• With the depicted victim and/or perpetrator in the event of a criminal act.

Retention Period and Storage Location

The recorded footage is retained for 7 days from the time it is captured. In the event of an incident (e.g., theft, robbery), the footage is kept separately for 1 month, and if the incident involves a third party unrelated to the company, for 3 months.
The material is stored internally in the company under secure conditions and restricted access, limited only to authorized employees who are contractually bound to maintain confidentiality and safeguard the material.

Data Subjects’ Rights

Data subjects have the following rights:

• Right of access (to see if they have been recorded and obtain a copy).
• Right to restriction (e.g., prevent deletion for legal use).
• Right to object to the processing.
• Right to erasure (where applicable).
• Right to withdraw consent (provided that the processing is based on consent, and only in the case where the Company grants access to third-party data and the use of consent is assessed as an appropriate legal basis for such data transfer).

To exercise their rights, data subjects may contact:

• By email at: gdpr@pearl-rail.com
• Or by letter to the company’s postal address:
  85 Akti Miaouli & 2 Flessa St., Piraeus, 18538, Greece

Right to File a Complaint

If you believe that personal data protection legislation has been violated, you have the right to file a complaint with the Hellenic Data Protection Authority (HDPA):

• Address: 1-3 Kifisias Ave., 11523 Athens, Greece
• Website: https://www.dpa.gr
• Phone: +30 210 6475600
• Email: complaints@dpa.gr