www.dataprotection.ro<\/a><\/p>\nPolicy on the processing of personal data obtained through the use of video surveillance means<\/strong><\/p>\n\n- Purpose of processing through video means
\nMINERVA 92 SRL processes personal data, specifically images, through video systems for the purpose of monitoring access to the institution, ensuring the security of the institution’s spaces and assets, as well as the safety of persons within the institution’s premises.
\nMINERVA 92 SRL uses the video surveillance subsystem to ensure the safety and security of the institution. This subsystem complements the detection and alarm systems for burglary attempts, access control, and fire detection, signaling, and alarm, thus forming an integrated physical security system.
\nSince the processing of personal data (the image) through video surveillance is mandatory, a person’s refusal to provide such data will result in the cancellation of their access to the premises of Hotel Minerva.<\/li>\n<\/ol>\nThis policy establishes:
\na. a uniform set of rules governing the implementation and use of the video surveillance system to ensure the security of persons and property, the guarding and protection of assets, buildings, valuables, and special-regime materials used in the activity of Minerva 92 SRL, while respecting the institution’s obligations as a data controller under data protection legislation and the security measures adopted for the protection of personal data, privacy, legitimate interests, and the guarantee of the fundamental rights of the data subjects.
\nb. the responsibilities regarding the administration and operation of the video surveillance system, as well as those regarding the drafting, endorsement, and approval of documents related to these activities.<\/p>\n
The Policy on the processing of personal data obtained through the use of video surveillance means of Minerva 92 SRL describes the institution’s video surveillance system and the protection measures taken by the institution’s president to protect personal data, privacy, and other fundamental rights and legitimate interests of the persons filmed by the video cameras. 2<\/p>\n
\n- Legitimacy Conditions<\/li>\n<\/ol>\n
The processing of personal data through the use of video surveillance means, as well as the installation and technical use of the equipment and components of the video surveillance system, is carried out in accordance with the legal provisions in the field:
\na. Regulation no. 679\/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95\/46\/EC (General Data Protection Regulation \u2013 GDPR);
\nb. The Guidelines of the European Data Protection Supervisor on video surveillance, published on March 17, 2010, Brussels;
\nc. Decision no. 52\/2012 on the processing of personal data through the use of video surveillance means, issued by the president of the National Supervisory Authority for Personal Data Processing (ANSPDCP);
\nd. Law no. 333\/2003 on the guarding of objectives, assets, values, and the protection of persons, republished, with subsequent amendments and completions;
\ne. Decision no. 301 of April 11, 2012, for the approval of the Methodological Norms of Law no. 333\/2003 on the guarding of objectives, assets, values, and the protection of persons;
\nf. The Methodological Norms for the application of Law no. 333\/2003, approved by GD no. 301\/2012, with subsequent amendments and completions;
\ng. Order no. 52\/2002 on the approval of Minimum Security Requirements for personal data processing, issued by the Ombudsman;<\/p>\n
Video surveillance is used only when conventional means are considerably less effective in achieving the mentioned objectives, according to the risk analysis carried out at the company level.
\nMINERVA 92 SRL processes recorded images in compliance with the legal provisions in the field.<\/p>\n
\n- Monitored Areas
\nThe placement of surveillance cameras was carried out in accordance with current legislation and based on the risk analysis performed at the institution level.
\nAreas where there is a high level of privacy expectations (offices where the public does not have access, restrooms, and other similar locations) are not monitored.
\nVideo surveillance is used only when conventional means are considerably less effective in achieving the mentioned objectives.
\nThe following access areas, spaces intended for the public, and restricted\/prohibited access areas are monitored by video means:
\n\u2013 Access paths within the Minerva 92 SRL premises;
\n\u2013 Video cameras in the hotel reception and lobby;
\n\u2013 Video cameras in the restaurant area, bar, events area, kitchens, buffet, storage area, parking;<\/li>\n<\/ol>\nThe recording device is located in a space under permanent guard with restricted access, based on password access.<\/p>\n
\n- Transparency and Information<\/li>\n<\/ol>\n
MINERVA 92 SRL provides persons entering the video-surveyed area with the information provided by Art. 13 of the General Data Protection Regulation and Art. 11 of Decision no. 52\/2012, issued by the president of ANSPDCP.
\nIn this regard, the information provided in Art. 13 of the GDPR, accompanied by the corresponding icon, is brought to the attention of the data subjects clearly and permanently, through an “Information Note” poster displayed in the monitored locations, positioned at a reasonable distance from where the surveillance equipment is located, so that it can be seen by any person.<\/p>\n
\n- Privacy Protection and Information Security<\/li>\n<\/ol>\n
To protect the security of the video system and to increase the degree of life protection, the following technical and organizational measures have been introduced:
\n\u2013 limiting the storage time of the filmed material, in accordance with security requirements;
\n\u2013 storage media (digital video recorders) are located in secure spaces, protected by physical security measures;
\n\u2013 all users with access rights have signed the job description by which they undertake to comply with the legal provisions in the field of personal data processing;
\n\u2013 the right of access is granted to users only for those resources that are strictly necessary for the performance of their duties;
\n\u2013 the person who has the right to grant, modify, or cancel the access rights of users, according to the database access procedure, is the system administrator, designated for this purpose by the operator;
\n\u2013 the administrator\/physical security system officer designated for this purpose constantly maintains an updated list of all persons who have access rights to the video surveillance system, specifying the type of access;
\n\u2013 the personal data protection officer will be consulted before the installation of any new video system.<\/p>\n
At the same time, measures were taken to prevent any unlawful processing of personal data or unauthorized access to such data.<\/p>\n
\n- Access to personal data collected through the video surveillance system<\/li>\n<\/ol>\n
Access to recorded and live video images is limited to a small number of persons (employees of the institution) who can be clearly identified and is determined by the responsibilities specified in the job description (for what purpose and what type of access).
\nIn particular, MINERVA 92 SRL imposes limits regarding the persons who have the right:
\n\u2013 to view the filmed material in real time
\n\u2013 to view the recorded material: viewing recorded images will be done in justified cases, such as those expressly provided by law and security incidents, by the General Manager or their deputy.
\n\u2013 to copy, download, delete, or modify any filmed material: copying, downloading, deleting, or modifying any filmed material will be carried out by the personnel designated for the administration and maintenance of the surveillance systems, specifically the IT specialists of the company contracted to perform system maintenance (Danirom Security – there is a Personal Data Processing Agreement), with the approval of the General Manager of Minerva 92 SRL.
\nThe video system of Minerva 92 SRL is not intended to capture (e.g., through selective focus or orientation) or process images (e.g., indexing, profiling) that reveal “special categories of data.”
\nMINERVA 92 SRL does not intend to use the surveillance system on an ad hoc basis, i.e., in a temporary or circumstantial manner.
\nAny activity of disclosing personal data to third parties will be documented and subject to a rigorous analysis regarding, on one hand, the necessity of the communication, and on the other hand, the compatibility between the purpose of the communication and the purpose for which these data were initially collected for processing (security and access control), but only after approval by the General Manager.
\nMINERVA 92 SRL has the obligation to make video recordings capturing the commission of criminal acts available to judicial authorities upon their written request, but only after approval from the General Manager has been obtained.
\nThe video surveillance system is not used for checking attendance or evaluating workplace performance.
\nIn exceptional cases, but respecting the guarantees described above, access may be granted to the disciplinary investigation committee within a disciplinary investigation, provided that the information helps investigate a crime or a disciplinary breach likely to prejudice the rights and freedoms of a person.
\nAll staff members with access rights to video recordings receive initial training in the field of data protection. Training is provided to every new staff member, and periodic workshops on data protection topics will be organized at least once every two years for all staff members who have access rights to the data.
\nAny security breach regarding the video surveillance subsystem is recorded in the GDPR Incident Register, and the General Manager is informed about this without undue delay, within a maximum of 12 hours.<\/p>\n
\n- System Description and Technical Specifications<\/li>\n<\/ol>\n
Conventionally, the video surveillance system is a static system. Its function is to record images and it is equipped with motion sensors. The system can record any movement detected by the cameras installed in the monitored area, along with the date, time, and location.
\nAll cameras are functional 24 hours a day, 7 days a week.
\nWhen necessary, the quality of the images allows for the recognition of those passing through the cameras’ field of action. For greater security in the processing of data obtained through video surveillance, the cameras are fixed (without a zoom function); thus, the user cannot modify the perimeter\/purpose of the surveillance. The system is used by Minerva 92 SRL for surveillance only. The system is maintained by the company Danirom Security, which provides service for the surveillance system but does not have the right to operate the system.<\/p>\n
\n- Benefits of the Surveillance System:
\n\u2013 increased control within the monitored perimeter, including entrances and exits;
\n\u2013 elimination of losses caused by unforeseen events;
\n\u2013 compliance with the acts, regulations, and legislation in force for high-risk objectives.<\/li>\n - Installation, Administration, and Operation of the System
\nThe equipment is installed such that only those spaces identified in the risk analysis as needing additional protection are under surveillance. Users of the video system are instructed not to monitor other types of areas.
\nImages captured by the video surveillance system are viewed in real-time only on the computer monitor in the data storage room.
\nUnauthorized access to the video system is not permitted.
\nAccess is strictly limited to system administrators and persons in the management of Minerva 92 SRL.
\nOn a case-by-case basis, access to the video system may be granted to other persons besides those mentioned above, only with the approval of the General Manager or their deputy. These persons will not have access to the personal data processed during the video surveillance activity.<\/li>\n - Disclosure of personal data collected through the video surveillance system
\nThe information recorded through the video surveillance systems is intended for use by MINERVA 92 SRL for the purpose of monitoring access to the institution, ensuring the security of the institution’s spaces and assets, as well as the safety of persons within the institution’s premises, and is made available to judicial bodies and other institutions authorized by law to request this information, upon their express request.
\nHowever, the system may constitute a means of investigation or obtaining information for internal inquiries or disciplinary procedures, including situations where a physical security incident occurs or criminal behavior is observed (in exceptional circumstances, images may be transferred to investigative bodies within a disciplinary or criminal investigation).
\nAny activity of transferring and disclosing personal data to third parties will be documented and subject to a rigorous evaluation regarding the necessity of the communication and the compatibility between the purpose of the communication and the purpose for which these data were initially collected for processing (security and access control), and will be done with the approval of the General Manager.
\nAny situation of disclosure will be recorded by the system administrator in the Register of disclosure cases.<\/li>\n<\/ol>\nThe images recorded through the video surveillance system installed on the premises of Hotel Minerva may be made available to judicial bodies upon their express request.<\/p>\n
\n- Storage Duration
\nThe storage duration of the data obtained through the video surveillance system is proportional to the purpose for which the data is processed; thus, images are stored for a period not exceeding 30 days, except for situations expressly regulated by law or duly justified cases.
\nUpon expiration of the storage period, the data is deleted via an automatic procedure in the order in which it was recorded.
\nIn the event of a security incident, as well as in duly justified cases, the retention period of the relevant filmed material may exceed the normal limits depending on the time required for further investigation of the security incident.
\nRetention is rigorously documented, and the necessity of retention is periodically reviewed (at a two-month interval) and will be done with the approval of the General Manager.
\nIf the storage duration exceeds the prescribed term of 30 days, this will be recorded in the Register of recordings exceeding the storage duration, managed by the system administrator.
\nThe company director will be consulted before the purchase or installation of any new protective video system.<\/li>\n - Rights of the Data Subject
\nMINERVA 92 SRL guarantees that it ensures compliance with the rights of data subjects, in accordance with Regulation no. 679\/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95\/46\/EC.
\nAll persons involved in video surveillance activities and those responsible for managing the filmed images will comply with the procedure for accessing personal data.
\nInformation for data subjects is provided clearly and permanently through an appropriate sign, a representative icon, with sufficient visibility and located in the monitored area, to signal the existence of surveillance cameras.
\nIn accordance with the provisions of Regulation no. 679\/2016, the data subject has the following rights regarding the processing of video images:
\n\u2013 the right of access
\n\u2013 the right to data erasure (“the right to be forgotten”)<\/li>\n<\/ol>\nIf the data subject has other questions regarding the processing of personal data concerning them by MINERVA 92 SRL, they may contact the Data Protection Representative at the e-mail address dpo@minerva.ro.
\nThe response to a request for access, intervention, or objection is provided within a maximum of 30 calendar days. This period may be extended by one month when necessary, taking into account the complexity and number of requests.
\nThe data subject will be informed of any such extension within 15 days of receiving the request, along with the reasons for the delay.
\nIf the data subject submits a request in electronic format, the information is provided in electronic format where possible, unless the data subject requests another format.
\nThe applicant may specify in the request if they wish the information to be communicated to a specific address, which may also be an e-mail address, or through a correspondence service that ensures delivery is made only in person.
\nIf the request is submitted through a representative, their identity data and the power of attorney granted for this purpose must be communicated.
\nIf requests from a data subject are manifestly unfounded or excessive, particularly due to their repetitive nature, MINERVA 92 SRL may:
\n\u2013 either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the requested actions;
\n\u2013 or refuse to act on the request.
\nIn the event of reasonable doubts concerning the identity of the natural person submitting the request for the exercise of one of the mentioned rights, MINERVA 92 SRL may request additional information necessary to confirm the identity of the data subject.
\nIf there is an express request from the data subject, they may be granted the right to view the recorded images concerning them or may be sent a copy of them. The images provided will be clear, to the extent possible, provided they do not prejudice the rights of third parties (the data subject will only be able to view their own image; the images of other persons who may appear in the recording will be edited so that their recognition\/identification is not possible). In the case of such a request, the data subject is obliged to identify themselves beyond any suspicion (to present an identity document when participating in the viewing) and to mention the date, time, location, and circumstances under which they were recorded by the surveillance cameras.
\nAdditionally, the data subject will provide a recent photograph so that the designated users can identify them more easily in the filmed images. The person will only be able to view their own image; the images of other persons who may appear in the recording will be edited so that their recognition\/identification is not possible.
\nThere is the possibility of refusing the right of access in situations where the exceptions provided by law apply. The necessity to restrict access may also be required if there is an obligation to protect the rights and freedoms of third parties\u2014for example, if other people appear in the images and it is not possible to obtain their consent or if irrelevant personal data cannot be removed through image editing.
\nTo exercise the aforementioned rights, the data subject must submit a written, dated, and signed request to the address:
\nMINERVA 92 SRL
\nGheorghe Manu 2-4, District 1, Bucharest, Postal Code 010445
\nOr via e-mail: dpo@minerva.ro<\/p>\n","protected":false},"excerpt":{"rendered":"
PRIVACY AND PERSONAL DATA PROCESSING POLICY Hotel Minerva & Nan Jing Restaurant Minerva 92 (hereinafter referred to as “the Company”) is a Romanian legal entity, headquartered in Bucharest, 2-4 Gheorghe Manu Street, District 1, Bucharest. The Company knows how important privacy is to our customers and strives to clearly explain how we collect, use, disclose, … <\/p>\n
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