Protocol cameratoezicht (Eng)
Introduction
Camera surveillance provides an important contribution to protecting the safety of employees, visitors
and residents. The preventive effect of camera surveillance prevents and deters the occurrence of
incidents. It also allows incidents to be handled correctly if the facts of the incident are captured on
camera.
However, camera surveillance does invade the privacy of residents, employees and visitors. Hence,
careful consideration is required between the purposes served by the camera surveillance (see Article
1 of the Protocol) and the resulting invasion of privacy. Moreover, the invasion must be kept to a
minimum and it must not be possible to achieve the objective by other, less invasive means. 1 Camera
surveillance is allowed only after carefully weighing these interests.
The lawful use of camera surveillance requires rules that establish what is allowed and what isn’t.
These rules are set out in this protocol. They cover the use of the cameras, 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 Laan van het Omniversum near number 14
It is, of course, also possible for the camera surveillance protocol to be applied at other GOO locations
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 as those in the GDPR.
Data Protection Authority
The Dutch Data Protection Authority (DPA) monitors compliance with the legal rules on the protection
of personal data.
Data subject(s)
Persons whose images were recorded (employees, residents and visitors of the GOO locations).
Security staff
1 To this end, an investigation was conducted (a so-called Data Protection Impact Assessment, DPIA),
which concluded that the infringement is justified.
Camera surveillance protocol forGOO locations in the Municipality of Apeldoorn 2024
Employees of a security company in charge of the direct supervision of the GOO site.
Camera system
The entire system of cameras placed in, or aimed at, areas in the buildings and the outside of these
buildings.'
Camera surveillance
Camera surveillance is the monitoring of a building, area or group(s) of people with the aid of cameras.
The emphasis with camera surveillance is on surveillance: footage is viewed even when there are no
ongoing incidents. One of the main purposes of camera surveillance is the prevention of incidents. The
aim is for observants to observe any incidents occurring and to provide an immediate response, for
instance directing police, security personnel or emergency workers to the incident to allow immediate
action to be taken.
GOO location (Municipal Refugee Centre)
Dutch abbreviation for: Municipal Reception Centre for Ukrainians. GOO locations comprise buildings
and the adjoining grounds used by the Municipality of Apeldoorn to accommodate refugees from
Ukraine.
Incident
An accident, nuisance event, criminal offence or 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
location that requires action by the controller.
Location Coordinator
The employee organising and facilitating the reception of Ukrainians at one of the GOO locations on
behalf of the Municipality of Apeldoorn.
Location Manager
The employee managing the location on behalf of the Municipality of Apeldoorn and who is
responsible for matters transcending an individual GOO location.
Municipal Duty Officer
The employee put in charge by the Municipality of Apeldoorn of the operational management of the
location coordinators and employees at the GOO locations outside regular working hours.
Project Leader
The employee or his or her alternate responsible for the reception of Ukrainians at the GOO locations
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 camera surveillance
a. Specifically, the camera surveillance serves the following purposes:
I. the protection of health and safety in and around GOO locations;
II. securing access to the GOO locations;
III. protecting property of the municipality, landlord, residents and employees from theft and damage;
IV. the recording of incidents.
b. Camera surveillance 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 camera surveillance is carried out under the responsibility of the College of Mayor 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 made, and internally documented, a balancing of interests
before relying on this basis.
b. Appropriate technical and organisational measures have been taken to secure camera footage
and the camera system. The necessity, subsidiarity and proportionality of these measures have
been carefully considered. These considerations are also documented.
c. Security staff, location coordinators, location managers, duty officers and the (acting) project
leader are authorised to view ‘live’ footage.
d. The location manager or, in the absence thereof, the (acting) project leader or, in the absence
thereof, the duty officer are authorised to watch the footage back. Watching footage back is
allowed only in the presence of two of the aforementioned persons (four-eyes principle). Should it
not be possible for two of these persons to be present, one of them may watch the footage back
in the presence of the location coordinator.
e. Footage will only be watched back in the event incidents have occurred and/or if images are
requested by authorised third parties.
f. In the event of an incident that requires 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. For this purpose, the Facilities Team Manager uses installer/maintenance
partner with whom contracts have been signed.
Article 4 The camera system, security and retention periods
a. Camera surveillance takes place through a closed 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 of time if an incident has occurred and the footage is
required for handling the incident. As soon as they are no longer necessary, the footage is
removed from the storage medium.
Article 5 Privacy of employees, residents and visitors
a. Camera surveillance is compatible with the purpose of security and surveillance. The footage will
only be used for the purpose of camera surveillance referred to in Article 2.
b. Camera surveillance will only be used in the general areas of the GOO location. This means that
parking spaces 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 camera surveillance in the sleeping and living areas, the toilets and showers,
treatment rooms of caregivers or any other areas that are part of the residents’ personal
environment.
d. Camera surveillance takes place for 24 hours a day.
e. The personal data processes are exclusively:
The footage;
Metadata relating to 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 to the extent 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, public prosecutor or
magistrate.
c. The person receiving the footage on behalf of the police, the public prosecutor or the magistrate
must identify him or herself and sign for 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 recoded in a journal.
Article 7 Confidentiality
Any person authorised to view the footage or who processes the footage on behalf of the controller
shall be bound to secrecy of all that becomes known to him or her within this capacity, unless there is
a statutory requirement for the 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 only has the right to inspect the images that show the data subject. The
request of the data subject must include the date and time the footage was recorded.
c. Prior to 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 camera surveillance
a. The Municipality of Apeldoorn announces the recording of footage via information boards at
the GOO locations.
b. The Municipality of Apeldoorn provides more extensive information to data subjects in
accordance with Article 13 of the GDPR. This information will be provided in the form of
posters and brochures.
Article 10 Complaints
A data subject may file a complaint about the processing of their personal data with the Data
Protection Officer of 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’.
