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Agricultural Winemaking Cooperative of Tyrnavos

Video Surveillance Policy

Information Notice on the Processing of Personal Data through a Video Surveillance System

This notice concerns the processing of personal data through the video surveillance system used by the Agricultural Winemaking Cooperative of Tyrnavos (tirnavoswinery.gr) for the protection of individuals and property. In this context, we inform you about the purpose and legal basis of the processing, the retention period of the footage, the recipients of the data, and your rights under the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679).

1. Data Controller

The AGRICULTURAL WINEMAKING COOPERATIVE OF TYRNAVOS, based in Tyrnavos, 1st km of the Tyrnavos–Larissa road, Greece, tel. +30 24920 22002.

2. Purpose and Legal Basis of Processing

We use a video surveillance system for the purpose of protecting individuals and property. The processing is necessary for the purposes of the legitimate interests pursued by us as the data controller (Article 6(1)(f) GDPR).

3. Assessment of Legitimate Interests

Our legitimate interest lies in the need to protect our premises and the property located therein against unlawful acts, such as theft. The same applies to safeguarding the life, physical integrity, health and property of our employees and third parties who are lawfully present in the monitored area.

We collect image data only and restrict surveillance to areas where we have assessed that there is an increased likelihood of unlawful acts, such as theft, for example at our cash register and entrance. We do not focus on areas where the privacy of individuals whose images are captured may be disproportionately affected, including their right to the protection of their personal data.

4. Recipients

The retained footage is accessible only to our competent/authorised personnel who are responsible for the security of the premises.

The footage is not disclosed to third parties, except in the following cases:

a) To the competent judicial, prosecutorial and police authorities, when it contains information necessary for the investigation of a criminal offence concerning individuals or property of the data controller.

b) To the competent judicial, prosecutorial and police authorities, when they lawfully request data in the performance of their duties.

c) To the victim or perpetrator of a criminal offence, where the data may constitute evidence of the offence.

5. Data Retention Period

We retain the data for seven (7) working days, after which it is automatically deleted.

If an incident is identified during this period, we isolate the relevant segment of the video footage and retain it for up to one (1) additional month for the purpose of investigating the incident and initiating legal proceedings to defend our legitimate interests. If the incident concerns a third party, we retain the footage for up to three (3) additional months.

6. Rights of Data Subjects

Data subjects have the following rights:

  • ΔRight of access: You have the right to know whether we process images of you and, if so, to obtain a copy of them.
  • Right to restriction of processing: You have the right to request that we restrict processing, for example, by asking us not to delete data that you consider necessary for the establishment, exercise or defence of legal claims.
  • Right to object: You have the right to object to the processing.
  • Right to erasure: You have the right to request the deletion of your personal data.

You may exercise your rights by sending an email to engineering@tirnavoswinery.gr or manager@tirnavoswinery.gr, by sending a letter to our postal address, or by submitting your request in person at our premises.

To enable us to examine a request relating to your image, you should specify approximately when you were within the range of the cameras and provide us with an image of yourself. This will help us identify your personal data and obscure the data of other individuals appearing in the footage.

Alternatively, you may visit our premises so that we can show you the footage in which you appear.

Please note that exercising the right to object or the right to erasure does not necessarily result in the immediate deletion of data or a change in processing. In all cases, we will provide you with a detailed response as soon as possible and within the time limits prescribed by the GDPR.

7. Right to Lodge a Complaint

If you believe that the processing of your personal data infringes Regulation (EU) 2016/679, you have the right to lodge a complaint with a supervisory authority.

The competent supervisory authority in Greece is the Hellenic Data Protection Authority (HDPA).

Address: 1–3 Kifisias Avenue, 115 23 Athens, Greece
Website: https://www.dpa.gr/
Telephone: +30 210 6475600