Information on the protection of personal data in matters of video surveillance
The Company Azienda Veneziana della Mobilità S.p.A. (hereinafter AVM or Company) manages and provides the urban public transport service of the municipalities of Venice and Chioggia, the suburban transport service of the central-southern area of the Metropolitan City of Venice, as well as the private and integrated mobility services of the municipality of Venice (parking garages, peripheral car parks, bike sharing, dockyards, etc.).
It is the parent company of the AVM Group and controls ACTV S.p.A. and Ve.La. S.p.A.
To supply the services mentioned previously, AVM provides the customer with tickets or other forms of ticketing also through the websites www.avmspa.it, www.actv.it, www.veneziaunica.it and the AVM Venezia Official App.
AVM is the processing controller of the personal data collected.
HOW WE COLLECT YOUR PERSONAL DATA
AVM uses a video surveillance system 24 hours a day in the area of offices, people movers, parking areas, dockyards, waterbus stops, check point ztl bus, bikepark and bikesharing. Images taken by AVM will be processed with the aid of electronic tools and in compliance with the law on personal data protection and the general provision of 8 April 2010 of the personal data protection supervisor, which does not require prior preventive consent from the data subject.
WHAT PERSONAL DATA CONCERNING YOU MAY BE COLLECTED
The following categories of personal data concerning you may be collected:
images of natural persons, as well as identification data concerning the means of transport
FOR WHAT PURPOSES YOUR PERSONAL DATA MAY BE USED
The processing of personal data by European data protection legislation must be subject to one of the various legal requirements, and we are obliged to indicate these requirements for each processing operation described, as you can read below:
a) Management of the video surveillance system
The purpose is the security and protection of company assets. The legal ground is the pursuit of the controller’s legitimate interest.
HOW WE KEEP YOUR PERSONAL DATA SAFE
AVM uses a wide range of security measures to improve the protection and maintenance of the security, integrity and accessibility of your personal data.
All of your personal data is stored in secure servers and is accessible and usable according to our security standards and policies.
The recorded images are digitally encoded and stored in encrypted form (in order to make it impossible to view them without a specific program) on the company server; servers are located in rooms with controlled access. The computerised system that manages the video surveillance equipment is provided with electronic authentication keys (password system), differentiated according to the operational management profile to which the user is enabled; it also keeps a record of all accesses and the ID/profile used.
We adopt, among other measure, measures such as:
the strict restriction of access to your personal data, on a need-to-know basis and for the sole purpose communicated, perimeter security systems to prohibit unauthorised access from the outside, the permanent monitoring of access to information systems to detect and stop the abuse of personal data, six-monthly penetration tests aimed at highlighting any leaks in perimeter security.
HOW LONG WE RETAIN YOUR INFORMATION
We store your personal data only for the time necessary to achieve the purposes for which it was collected or for any other legitimate purpose related to it.
The images captured on camera are stored for a maximum of 5 days.
They are then deleted by using automatic mechanisms (overwriting).
Should we need to defend ourselves or take action or even make claims against you or third parties, we may retain the personal data we deem necessary to process for such purposes, for the time that such claim can be prosecuted.
WITH WHOM WE MAY SHARE YOUR PERSONAL INFORMATION
Your personal data may be accessed by employees of AVM, as well as by suppliers and collaborators, duly appointed data processors, who provide support for the provision of services, and by public entities that can access them by law (e.g. judicial authority and public security authority).
If you have any questions regarding our processing of your personal data, please use the web form "privacy" in the "contacts" section of the site ww.avmspa.it or contact the telephone number +390412722111, asking the secretariat of the Legal and Corporate Affairs.
We would also like to inform you that the Company has appointed an external data protection officer (DPO), whose contact details are firstname.lastname@example.org, to whom you may apply in general for matters relating to the protection of personal data and related rights.
YOUR DATA PROTECTION RIGHTS AND YOUR RIGHT TO LODGE COMPLAINTS WITH THE SUPERVISORY AUTHORITY
You have the right to ask us, under the legal conditions, in particular:
- access to your personal data
- the deletion of any data for which we no longer have any legal basis for processing
- the limitation and objection to the way in which we process your personal data, in the cases provided for by law.
Should you exercise any of the aforementioned rights, it will be our responsibility to verify that you are entitled to do so and, as a rule, we will give you feedback within one month.
If you are not satisfied with the way in which we process your personal data or with our feedback, you have the right to lodge a complaint with the supervisory authority, the contact details of which can be found on the website www.garanteprivacy.it