CCTV Surveillance Protocol (Eng)

Introduction

CCTV makes an important contribution to ensuring the safety of employees and visitors
and residents. The preventive effect of CCTV surveillance prevents and deters the occurrence of
incidents. It also ensures that incidents are dealt with correctly if the facts of the incident are recorded on
camera.

However, CCTV does infringe on the privacy of residents, employees and visitors. Hence,
Careful consideration must be given to the purposes served by CCTV surveillance (see Article
1 of the Protocol) and the resulting invasion of privacy. Moreover, the invasion must be limited to a
minimum, and it must not be possible to achieve the objective by other, less invasive means. 1 Camera
Surveillance is permitted only after these interests have been carefully weighed up.

The lawful use of CCTV requires rules setting out what is permitted and what is not.
These rules are set out in this protocol. They cover the use of the cameras and the viewing of the footage
and the storage of the footage.

Cameras are installed in and around the following GOO locations:

• GOO location CB, Anklaarseweg 91 (4th floor)
• GOO location CG, Christiaan Geurtsweg 10
• GOO location DT, Deventerstraat 184
• GOO location VW, Watermanstraat 30
• Car park on Laan van het Omniversum, near number 14
  It is, of course, also possible for the CCTV protocol to be applied at other GOO sites
  in the future. This will be decided in due course.

Article 1 Definitions

General Data Protection Regulation
The General Data Protection Regulation (GDPR). This European regulation provides the legal
framework for the processing of personal data. The terms used in this protocol have the same
meaning the same as those in the GDPR.

Data Protection Authority

The Dutch Data Protection Authority (DPA) monitors compliance with the legal rules on the protection
or personal data.

Data subject(s)

People whose images were recorded (employees, residents and visitors to the GOO sites).

Security staff

1 To this end, an investigation was carried out (a so-called Data Protection Impact Assessment, DPIA),
which concluded that the infringement is justified.

CCTV surveillance protocol for GOO sites in the Municipality of Apeldoorn 2024
Employees of a security company responsible for the direct supervision of the GOO site.

Camera system

The entire system of cameras installed in, or directed towards, areas within the buildings and the exterior of these
buildings.’

CCTV 

CCTV is the monitoring of a building, an area or a group or groups of people using cameras.
The focus of CCTV is on surveillance: footage is viewed even when there are no
ongoing incidents. One of the main purposes of CCTV is to prevent incidents. The
The aim is for observers to observe any incidents that occur and to respond immediately, for
instance of directing police, security personnel or emergency services staff to the scene to enable immediate
action to be taken.

GOO location (Municipal Refugee Centre)

Dutch abbreviation for: Municipal Reception Centre for Ukrainians. GOO sites consist of buildings
and the adjoining grounds used by the Municipality of Apeldoorn to house refugees from
Ukraine.

Incident

An accident, a nuisance, a criminal offence or a suspicion thereof, and/or an event that constitutes a
danger or imminent danger to the health or safety of people or property in and around the GOO
a location that requires action by the controller.

Location Coordinator

The employee organising and facilitating the reception of Ukrainians at one of the GOO sites on
on behalf of the Municipality of Apeldoorn.

Location Manager

The employee who manages the site on behalf of the Municipality of Apeldoorn and who is
responsible for matters that go beyond a single GOO site.

Municipal Duty Officer

The employee appointed by the Municipality of Apeldoorn to be in charge of the operational management of the
location coordinators and staff at the GOO sites outside normal working hours.

Project Leader

The employee or their deputy responsible for receiving Ukrainians at the GOO sites
on behalf of the Municipality of Apeldoorn and who acts as the person with final responsibility for the
project organisation.

Article 2: Processing and purpose of CCTV surveillance

a. Specifically, the CCTV surveillance serves the following purposes:
I. the protection of health and safety in and around GOO sites;
II. ensuring access to the GOO sites;
III. protecting the property of the local authority, the landlord, residents and employees from theft and damage;
IV. The recording of incidents.
b. CCTV will not be used to track and/or monitor employees. 2
2 As referred to in section 27(1) of the Works Councils Act

Article 3 Duties and responsibilities

a. The CCTV surveillance is carried out under the responsibility of the Mayor’s Office and
Aldermen (the Municipal Executive). The Municipal Executive is therefore a data controller within
the meaning of the GDPR. The Municipal Executive bases this on the legitimate interest
condition. The Municipal Executive has carried out, and documented internally, a balancing of interests
before relying on this basis.

b. Appropriate technical and organisational measures have been put in place to safeguard the camera footage
and the camera system. The necessity, subsidiarity and proportionality of these measures have
has been carefully considered. These considerations are also documented.

c. Security staff, location coordinators, location managers, duty officers and the (acting) project
Leaders are authorised to view ‘live’ footage.

d. The location manager or, in their absence, the (acting) project leader or, in the absence
In this regard, the duty officer is authorised to review the footage. Reviewing the footage is
permitted only in the presence of two of the aforementioned persons (the four-eyes principle). Should it
If it is not possible for two of these people to be present, one of them may watch the footage back
in the presence of the location coordinator.

e. Footage will only be reviewed in the event that incidents have occurred and/or if images are
requested by authorised third parties.
f. In the event of an incident requiring an investigation, the (acting) project leader may:

evaluate the footage;

if the investigation requires the footage to be stored, copy or transfer the relevant footage to
a separate new storage medium.

g. Technical management and maintenance of the camera system are carried out by the Facilities

Team Manager. To this end, the Facilities Team Manager utilises the services of an installer/maintenance technician
a partner with whom contracts have been signed.

Article 4: The CCTV system, security and retention periods

a. CCTV surveillance is carried out via a closed-circuit system. Footage is stored digitally on a hard
disk or similar storage medium: the system and storage medium are located in a locked room
accessible only with a pass, code or key.

b. The cameras do not record sound.

c. The footage is stored for 14 days. After this, the images are automatically overwritten by new
footage.

d. Footage may be stored for a longer period if an incident has occurred and the footage is
required for dealing with the incident. As soon as it is no longer needed, the footage is
removed from the storage medium.

Article 5 Privacy of employees, residents and visitors

a. CCTV is used for security and surveillance purposes. The footage will
shall only be used for the purposes of camera surveillance as referred to in Article 2.

b. CCTV will only be used in the general areas of the GOO site. This means that
car parks and other outdoor areas forming part of the GOO site, entrances, communal
cooking and dining areas, halls, corridors, waiting areas, recreation and play areas, and other
Common areas may be filmed.

c. There is no CCTV in the sleeping and living areas, the toilets and showers,
treatment rooms, carers’ rooms or any other areas that form part of the residents’ personal
environment.

d. CCTV surveillance operates 24 hours a day.

e. The personal data processing operations are exclusively:

The footage;

Metadata relating to the time, date, location and the camera used to film the footage.

Article 6 Access to and the provision of recorded footage

a. Access to camera footage is restricted as far as possible. Only designated officials have
access to the camera system and camera footage.

b. Footage will only be transferred to, and at the request of, the police, the public prosecutor or
magistrate.

c. The person receiving the footage on behalf of the police, the public prosecutor or the magistrate
must identify themselves and sign to confirm receipt of the footage.

d. Footage will only be provided to third parties if there is any (legal) obligation to do so and if this is
compatible with the purpose of collecting the footage as referred to in Article 1 of this protocol.

e. Any provision of footage to third parties is recorded in a log.

Article 7 Confidentiality

Any person authorised to view the footage or who processes the footage on behalf of the data controller
shall be bound to maintain the confidentiality of all information that comes to his or her knowledge in this capacity, unless there is
a statutory requirement for disclosure, or the necessity of disclosure, arises from his or her duties.

Article 8 Rights of data subjects

a. Any data subject may submit a request to the controller to exercise their rights in relation to
their personal data.

b. The data subject is only entitled to inspect the images in which the data subject appears. The
The data subject’s request must include the date and time the footage was recorded.

c. Before being granted access to the footage, the data subject must provide proof of identity to
the (acting) project leader or the location manager.

d. A request as referred to in this article must be submitted via privacy@apeldoorn.nl.

Article 9 Provision of information regarding CCTV surveillance

a. The Municipality of Apeldoorn announces that footage is being recorded via information boards at
the GOO locations.

b. The Municipality of Apeldoorn provides more detailed information to data subjects in
in accordance with Article 13 of the GDPR. This information will be provided in the form of
posters and leaflets.

Article 10 Complaints

A data subject may lodge a complaint regarding the processing of their personal data with the Data
Protection Officer for the Municipality of Apeldoorn via fg@apeldoorn.nl.

Article 11 Final provision

This protocol may be cited as ‘Camera surveillance protocol for municipal reception centres for
’Ukrainians in the Municipality of Apeldoorn 2024’.