Transparency and a confidential handling of your personal data is an important foundation for good cooperation. We therefore inform you about how we process your personal data in accordance with statutory provisions and how you can exercise your rights.
1. Controller
The Controller responsible for processing your personal data is the company listed on the information sign for video surveillance and vehicle number plate recognition at the respective site.
2. How can you contact the Data Protection Officer?
You can contact our Group Data Protection Officer at:
RWE AG
Data Protection Officer
RWE Platz 6
45141 Essen
E-Mail at [email protected]
3. What personal data of yours do we process and for what purpose?
The Controller monitors the security-relevant areas inside and outside its buildings and premises by means of video recording and video transmission (live streams). As a matter of principle, general video surveillance of public spaces does not take place.
The video surveillance serves to protect property and premises as well as to avert dangers to the security of operations. It pursues the objective of ensuring the safety of employees and other persons on the operational premises and enables the exercise of property rights. In addition, the video surveillance serves to detect and report security-relevant events, for example through the use of intelligent video image analysis and event-driven image switching. It supports the timely verification of incidents as well as the replacement or supplementation of person-based control rounds in the form of so-called virtual rounds. Furthermore, the video surveillance enables the investigation of facts and traceability of security-relevant occurrences or actions against the company, its employees or third parties, including the preservation of evidence and, where applicable, subsequent use of evidence. Finally, it also serves to initiate and coordinate appropriate intervention measures in the event of an incident.
Furthermore, the Controller offers automated number plate recognition at selected RWE operational sites. This service enables you to use the premises more conveniently by allowing you to enter without manually presenting your access card. If you decide to use this service, the Controller will process general data about you (name, personnel number, company and place of work, timestamp) as well as the vehicle number plates including country codes intended for authorisation. In addition, number plate recognition at individual designated operational sites serves the proper handling of logistical and operational processes.
4. What are the sources of the data?
The provision of video data occurs through presence in the recording area of video surveillance and number plate recognition systems. At locations where video surveillance takes place, this is indicated by an appropriate information sign.
In addition, you have the option of providing the vehicle number plates to the Controller as part of your voluntary registration for the automated number plate recognition service at sites where the system is used. The number plates are linked with the associated general data about you (name, personnel number, company, place of work, timestamp), which you have already provided to RWE for access control by means of your RWE company or visitor pass, and are processed at the relevant RWE operational sites.
Where video surveillance is legally required in certain areas, we cannot permit presence without provision of the data. In all other cases, video surveillance can be waived, provided that you notify us of your justified objections in advance (objection) and we cannot demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms (balancing of interests). For automated number plate recognition, the provision of data is required. Profiling does not take place.
5. What are the legal grounds for data processing?
The use of video surveillance is based on the legitimate interests of the Controller and, where applicable, the legitimate interests of third parties. The purposes of video surveillance are described in detail in Section 3. In addition, in individual cases there may be a legal obligation to carry out video surveillance of certain areas at individual sites. In such cases, the relevant statutory provision forms the additional legal basis for data processing. Where data of employees is processed in the context of video surveillance, performance of the employment relationship as well as the applicable works agreement may additionally be relevant as a legal basis.
Automated number plate recognition is essentially a voluntary and optional service offered by RWE. If you grant your explicit consent to the processing of personal data for this purpose, the lawfulness of this processing is based on your consent. In addition, number plate processing may also serve to protect legitimate interests of us or third parties (see Section 3).
6. Who has access to your data?
Access to your personal data is granted exclusively to departments and persons within the responsible company who require this data to fulfil contractual and statutory obligations or to implement legitimate interests. In addition, the respective Controllers have individual tasks and services carried out by carefully selected and commissioned (IT) service providers who are contractually obliged to comply with data protection and security requirements.
Video and number plate data is only evaluated in the event of a specific incident, such as violations of house rules or criminal offences. In such cases, the recordings may be handed over to competent security authorities (e. g. police or public prosecutor's office).
Transmission to third parties - such as companies affiliated with the Controller - only takes place if statutory provisions permit or require this, there is a legitimate interest, you have granted your consent or a contractual necessity exists.
7. Will your data be transferred to countries outside the European Union and the European Economic Area (so-called "third countries")?
Transfer of data to third countries is not intended.
8. How long will your data be stored?
Recorded data from video surveillance is generally only stored for a limited period and subsequently deleted. Longer storage only takes place if this is necessary for the preservation of evidence in the event of security-relevant incidents or suspicion of criminal offences. In such cases, the personal data is deleted as soon as the respective matter is concluded and no statutory retention obligations or other legitimate grounds prevent further storage.
The image data from vehicle number plate recognition as well as the associated master data and access data is only stored for as long as is necessary to achieve the respective purpose, and is subsequently deleted.
9. What data protection rights do you have?
Subject to the statutory requirements, you may assert the following rights:
- the right to obtain information on data processing and a copy of the personal data undergoing processing,
- the right to rectification of inaccurate or incomplete personal data,
- the right to obtain the erasure of personal data, provided there is no legal reason or overriding legitimate reason for further processing,
- the right to restriction of the processing,