Privacy policy on video surveillance art.13 Reg.679/2016 (GDPR) Reg. 679/2016 (GDPR)


  1. Object

This privacy policy (second layer information), which integrates the content of the first layer information referred to in the following art. 3, – pursuant to and for the purposes of art. 13 of Regulation (EU) 679/2016 (hereafter: GDPR), the provision of the Privacy Guarantor on video surveillance of 08/04/2010 and the EDPB guidelines on video surveillance adopted on 29 January 2020 – has the purpose of inform you about the methods of processing your personal data, acquired and processed through the video surveillance systems operating at the Plastotecnica Spa facilities, in compliance with the applicable legislation on the protection of personal data.


  1. Data controller

Plastotecnica Spa, with registered office in Viale dell’industria 5°strada, 2/1 Bagnoli di Sopra (hereafter: “Azienda”), e-mail address:


  1. First layer information pursuant to the EDPB guidelines on video surveillance

The video surveillance areas are marked with special warning signs, in accordance with the EDPB guidelines, clearly visible in all environmental lighting conditions. These signs are placed before the range of the cameras.


  1. Categories of data processed

For the purposes described in the following art. 5, the Data Controller processes your personal data, consisting of images, in real time and recorded, collected by the video surveillance system installed and operational at the facilities of Plastotecnica S.p.a.


  1. Purpose of the treatment

Plastotecnica s.p.a. uses video surveillance systems for the sole purpose of increasing the safety of workers employed within the production units and offices and company assets, by adopting suitable measures to prevent, prevent or otherwise hinder criminal acts within the own relevance. For this purpose, Plastotecnica s.p.a. has signed a trade union agreement, pursuant art. 4, co. 1, l. n. 300/1970, with which the use of the installed video surveillance system was agreed and regulated.


  1. Legal basis of the processing

The video surveillance activity is based on the pursuit of the legitimate interest of the Data controller in carrying out the processing for the purposes indicated in point 5) of this Privacy policy (GDPR art. 6, par. 1 letter f).


  1. Categories of data subject to processing

In relation to the purposes of the data processing referred to in point 5, only the personal data coming from the video surveillance system will be processed, i.e. the images, in real time and recorded, coming from the aforementioned circuit.


  1. Methods of processing and conservation of images

The treatment carried out through the video surveillance system of Plastotecnica spa, in line with the fundamental principles enshrined in Regulation (EU) 679/2016 (GDPR), is based on the principles of correctness, relevance and minimization of data, lawfulness, necessity, proportionality, in compliance with fundamental rights and freedoms, as well as the dignity of persons, with particular reference to the protection of privacy, personal identity and the right to protection of people’s personal data.

For the purposes indicated in point 5 only, the images taken by the cameras are viewed in real time, through dedicated monitors, by the personnel authorized by the Data Controller, and may be subject to recording and storage, within the limits and in the manner prescribed by current legislation and by the trade union agreement on video surveillance.

The retention time of the images is 72 ore, subject to special needs for further conservation in relation to holidays or office or plant closures, as well as in the event that a specific investigative request from the Judicial Authority or the Judicial Police must be adhered to.

Only in exceptional and precisely justified cases, a longer time for data retention may be allowed, which in any case must not exceed 7 days.


  1. Recipients or categories of recipients of personal data

The personal data acquired will not be subject to any automated decision-making process, including profiling, and will be completely deleted upon expiry of the deadline. The data processed will not be disseminated, communicated or transferred outside the European Union.

The images in real time can be viewed:

  • By staff, on the express mandate of the Data Controller;
  • By the company in charge of maintenance, which carries out its activity through its own personnel, specifically authorized to access the system within the limits of strictly indispensable with respect to the need for correct operation and maintenance interventions;
  • by the security company that patrols the company;
  • by the competent authorities in the event of a crime or investigation.

The recorded images can be viewed by the competent authorities in case it is necessary for their activities.


  1. Data subject’s rights

You can exercise all the rights recognized by Chapter III of EU Regulation 679/2016 (Article 15-22) by contacting the Data Controller at the contacts indicated above, also to request information or clarifications. Furthermore, if you believe that the processing of your personal data does not comply with the provisions of the GDPR, you are entitled to lodge a complaint with the Garante della privacy as the supervisory authority, based in Piazza di Monte Citorio, 121 – 00186 Rome, following the procedures and directions available on the website