CCTV log for (UA)
At the same time, CCTV infringes on the privacy of residents, staff and visitors. Therefore
It is necessary to carefully weigh up the purposes served by video surveillance (see Article 1 of the Protocol), and
the associated invasion of privacy. Video surveillance may be introduced for
the condition that the objective set cannot be achieved by other, simpler means, and at the same time
Intrusions into private life must be kept to a minimum. 1 Video surveillance may be
to be applied only once a balance of interests has been achieved.
In order to use the CCTV system properly, rules are required to define
the limits of what is permitted. These rules are set out in the protocol. They relate to the use of cameras,
viewing recordings and storing footage.
Cameras have been installed inside and around the following GOO sites:
- GOO «CB» building, Anklaarseweg 91 (4th floor)
- GOO «CG» site, Christiaan Geurtsweg 10
- GOO «DT» property, Deventerstraat 184
- GOO «VW» premises, Watermanstraat 30
- Car park on Laan van het Omniversum, near number 14
It is quite possible that this CCTV protocol will also apply in other GOO establishments.
A decision will be taken on this matter.
Article 1 Definitions
General Data Protection Regulation
General Data Protection Regulation (GDPR). This European regulation provides a legal
the legal basis for the processing of personal data. The terms used in this protocol,
have the same meaning as in AVG.
Data Protection Supervisory Authority
The Data Protection Authority (AP) monitors compliance with legal provisions
regarding the protection of personal data.
Parties involved
People whose images have been recorded (staff, residents and visitors to GOO premises).
Security service staff
1 To this end, an assessment of the current circumstances (known as a DPIA) was carried out, the results of which
showed that such an invasion is justified.
Staff of the security company who are responsible for providing direct security for the site
GOO.
Camera system
A network of cameras located inside and outside buildings, or directed towards them.
CCTV
Video surveillance is the monitoring of a building, an area or a group (or groups) of people using
cameras. The term «video surveillance» emphasises the act of surveillance: video recordings
are reviewed even when no incidents occur. An important objective
CCTV is used to prevent incidents. If an incident does occur, the task is
The role of observers is to record it and ensure an immediate response,
For example, by making the police, managers or staff of emergency and rescue services
the scene of the incident, so that timely measures can be taken.
GOO Facility (Municipal Reception Centre for Refugees from Ukraine)
Abbreviation for: Municipal Shelter Ukraine. GOO facilities are buildings and their surrounding areas
plots of land used by the municipality of Apeldoorn for the purpose of accommodating
refugees from Ukraine.
Incident
An accident, an unpleasant incident, a criminal offence or a suspicion that one has been committed
an event that poses a danger or an imminent threat to the health of persons or the safety of property at
at and near the GOO site and requires the controller’s intervention.
Admissions Centre Coordinator
An employee who was commissioned by the municipality of Apeldoorn to organise and facilitate
the admission of Ukrainians to one of the GOO facilities.
Head of the Admissions Centre
An employee who was commissioned by the municipality of Apeldoorn to manage the facility and
resolving issues that go beyond the scope of a single GOO facility.
Next
An employee who has been appointed by the municipality of Apeldoorn to carry out duties
co-ordinators at reception centres and staff at GOO facilities outside working hours.
Project Manager
An employee or their deputy, to whom the municipality of Apeldoorn has entrusted responsibility for
the reception of Ukrainians at GOO centres, and who bears ultimate responsibility on behalf of the organisation,
who is leading the project.
Article 2: Processing and the purpose of video surveillance
a. In particular, CCTV is used for the following purposes:
I. Protection of health and safety at and around GOO sites;
II. Securing the process of accessing GOO facilities;
III. Protection of the property of the local authority, the landlord, residents and staff against theft and
damage;
IV. Incident recording.
b. CCTV is not used for tracking and/or monitoring
staff. 2
Article 3 Duties and Responsibilities
a. Responsibility for the implementation of CCTV lies with the local executive body
local government (city administration); therefore, the city administration is the data controller in
within the meaning of the GDPR. In this regard, the city administration adheres to the principle of legitimate interest.
Before applying this principle, the city council carried out and documented
balance of interests.
b. Appropriate technical and organisational measures have been taken to protect the CCTV system and
recordings obtained from the cameras. The issues regarding the necessity were carefully considered,
the subordination and proportionality of these measures. These considerations have also been documented.
c. Security staff are permitted to view images in «real-time» mode,
co-ordinators and managers of reception centres, duty officers, project manager
(Acting Project Manager).
d. The head of the reception desk is permitted to view the images (= review the records)
the centre, or, in its absence, the project manager (acting project manager), or, in his
in the absence of — the duty officer. Records should be reviewed in the presence of two of the persons named
(the «four-eyes» principle). If two of the persons named are unable to be present, then one
Some of them may view the footage in the presence of the admissions coordinator
centre.
e. Video footage is only reviewed in the event of incidents and/or if the recordings
are requested by authorised third parties. f. In the event of an incident requiring an investigation, the project manager (acting project manager)
(project) has the authority to:
to assess the recording;
If the records are to be retained for the purposes of a subsequent investigation, they should be copied or
transfer the relevant records to a separate new storage medium.
g. Technical management and maintenance of the CCTV system are carried out by the head of
operations. To this end, the Head of Operations involves specialists/partners from the technical
services for which contracts have been concluded.
Article 4: CCTV system, security and retention periods for video recordings
a. Video surveillance is carried out via a closed-circuit system. The footage is stored in
in digital form on a hard disk or similar storage medium: the system and the storage medium are located
in a locked room, which can only be accessed with a pass, a code or
key.
b. The cameras do not record sound.
c. Records are stored for 14 days. After that, old records are automatically replaced by new ones.
d. Records may be retained for longer if an incident has occurred and they are required for its
further investigation. The records will be deleted as soon as they are no longer required.
Article 5: Confidentiality of staff, residents and visitors
a. CCTV is used for security and surveillance purposes. The footage recorded will be
be used solely for the purposes of video surveillance as defined in Article 2.
b. CCTV surveillance is carried out only in public areas at GOO premises. This
means that it is possible to film car parks and other open spaces belonging to
GOO premises, entrances, communal food preparation areas and canteens, lobbies, corridors, areas
waiting areas, rest and play areas, and other communal areas.
c. Video surveillance will not be carried out in bedrooms and living areas, toilets,
shower rooms, treatment rooms and other areas designated for personal use
residents’ living space.
d. CCTV surveillance operates 24 hours a day.
e. The personal data processed consists exclusively of:
Video recordings;
Metadata relating to the time, date, location and camera used to make the recording.
Article 6 Access to and transfer of filmed material
a. Access to camera footage is restricted as much as possible. Access to the camera system and
Only certain officials have access to the video recordings.
b. Video recordings will be handed over to the police, the public prosecutor or the investigating judge only upon request.
c. A person receiving a video recording on behalf of the police, a public prosecutor or an investigating judge must certify
identify themselves and sign to confirm receipt of the video recording.
d. Video recordings are provided to third parties only where there is a (legal) obligation to do so
to do so, provided that this is in line with the purpose of collecting video recordings as set out in Article 1 of this
the minutes.
e. Details of the transfer of video recordings are recorded in the logbook.
Article 7 Duty of confidentiality
Any person authorised to view video recordings or process them on behalf of
the data controller is obliged to keep confidential everything that comes to its attention from these video recordings, in accordance with
except where it is required to disclose information in accordance with legislation
provisions, or where the need for disclosure arises from its duties.
Article 8: Rights of data subjects
a. Any data subject may contact the data controller with a request regarding the implementation of
their rights in relation to their personal data.
b. The data subject has the right to view only those video recordings in which he or she may appear
present. In the request, the data subject must specify the date and time when the
videos that interest him.
c. Before being granted permission to view the video recordings, the data subject must confirm
to the project manager (or their acting replacement) or the head of the reception centre.
d. The enquiry referred to in this article should be sent to адресуprivacy@apeldoorn.nl.
Article 9: Notice regarding the installation of CCTV
a. The Municipality of Apeldoorn will display information on noticeboards at GOO sites
information stating that CCTV surveillance will be in operation.
b. The Municipality of Apeldoorn provides data subjects with more detailed information as appropriate
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
Data protection enquiries for the municipality of Apeldoorn at the following address fg@apeldoorn.nl.
Article 11 Final Provision
This protocol may be referred to as the «CCTV Protocol for GOO sites’
»Municipality of Apeldoorn, 2024".