CCVT POLICY
I. Scope of the CCVT Policy
This CCTV policy applies to all personnel, customers, relations, contractors, and visitors of Karl Lagerfeld who are visiting the Karl Lagerfeld head quarter offices and/or our stores. This policy relates directly to the location and use of CCTV, the monitoring, recording and subsequent use of such recorded material by Karl Lagerfeld and its sub-contractors. Karl Lagerfeld will ensure that CCTV systems, where installed, are operated only in a way that is compatible with the provisions of this policy. Inappropriate access or disclosure of this data will constitute a data breach and should be reported immediately to the company’s Information Security Officer and the Privacy Officer in accordance with the internal incident management procedure.
The data controller is KARL LAGERFELD International B.V. (hereinafter as “KARL LAGERFELD”, “KARL”, “we”, “us” or “our”). KARL LAGERFELD is a company incorporated in the Netherlands and the owner of KARL.COM, (international) stores, and the KARL LAGERFELD brand.
Registered number: 53647785
Registered office: Herengracht 182, 1016 BR Amsterdam, Netherlands
VAT registration number: NL850960678B0
II. Purposes of CCTV
We have carried out a Data Privacy Impact Assessment (DPIA) in accordance with article 35 GDPR and based on its findings it considers it necessary and proportionate to install and use a CCTV system in the Karl Lagerfeld headquarters and stores.
The data collected from the CCTV system will assist in:
- Prevention or detection of crime or equivalent malpractice
- Identification and prosecutions of offenders
- Monitoring of the security of the Karl Lagerfeld’s business premises.
- Identification of unauthorized actions or unsafe working practices that might result in disciplinary proceedings being instituted against employees and to assist in providing relevant evidence.
III. Legal basis of CCTV
We base the processing of your personal data in our camera surveillance on the legal basis 'legitimate interests' in article 6 (1) f GDPR.
This means that a balancing of interests between the interests served by the processing on the one hand and your privacy interests on the other has been carried out, and that the interests in favor of the processing outweigh the interests served. In this regard, our interests in processing personal data in the context of camera surveillance consist of achieving the purposes mentioned in the sub-paragraph "Purposes of CCTV" above.
When deploying a camera, we examine how this can be done in a way that infringes the privacy of the persons being filmed as little as possible. For example, where relevant, we consider, among other things:
- The type of camera used (infrared, color, black and white and the quality/detail of the images).
- The range of the camera and how it is adjusted.
- The camera's functions (e.g., face recognition or analysis capabilities);
- At what times camera surveillance takes place.
- Whether the camera images are recorded or not and - if so - for how long; and
- Who has access to the camera images under what conditions.
A separate document shows briefly how the applicable privacy requirements are met for each camera installed. Reasons are given for each camera for which purpose we have installed it, why the recording of images is necessary to achieve that purpose and which of the above-mentioned safeguards we have taken to prevent or limit any undesirable consequences for the privacy of the people being filmed.
IV. Location of CCTV
Cameras are located at strategic points throughout the Karl Lagerfeld’s business premises, principally at the main entrance. In the Karl Lagerfeld stores they are positioned in a way they provide clear images. No camera focuses, or will focus, on toilets, changing rooms, staff kitchen areas, staff rooms or private offices.
All cameras are clearly visible, and visitors will be informed by appropriate signs are prominently displayed at the entrance of our stores and the headquarters so that employees, customers, or other visitors are aware they are entering a Karl Lagerfeld property or office covered by CCTV.
V. Recording and retention of CCTV
Images produced by the CCTV application are intended to be clear as possible, so they are affective for the purposes set above. Maintenance checks of the cameras are undertaken on a regular basis to ensure it is working properly and images may be recorded in constant real-time (24 hours a day) throughout the year but will automatically be deleted and overwritten on recycling basis and will no longer kept than legally is permitted.
In certain situations, we process your personal data longer than the general rules based on the retention policy. This is the case, for example, when we need to process your personal data for longer:
- Incident. In the event of an incident, camera images may be kept longer to investigate and deal with the incident;
- Retention or legal obligation. To comply with a minimum retention period or other legal obligation incumbent on us under EU law or the law of an EU Member State;
- Procedure. Your personal data is required in the context of legal proceedings; or
- Freedom of expression. When further processing of your personal data is necessary for the exercise of the right to freedom of expression and information.
VI. Access and disclosure of CCTV is restricted.
Access to, and disclosure of images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. The images can only be disclosed in accordance with the purposes for which they were collected and in line with the privacy principles as included in the GDPR (EU) 2016/679.
Access to recorded images is limited to those who are authorized to do so only after approval by the Security and Privacy Officer according to the internal procedure designated for this purpose.
VII. Security
We consider protection of your privacy and personal data very important. We have therefore implemented appropriate technical and organizational measures to protect and secure personal data to prevent breaches of data confidentiality, integrity and availability. This also applies to personal data processing in the context of our camera surveillance. All employees and other persons engaged by Karl Lagerfeld to process personal data are thereby obliged to respect the confidentiality of personal data.
VIII. Privacy rights
Under the data protection laws, in articles 12 until 23 GDPR, individuals have the right to inspect how we process your personal data. This means that you are primarily entitled to a copy of the personal data, although in principle not to a copy of the documents containing these personal data. In the context of camera surveillance, this means that, in principle, you are entitled to a copy of the camera images, but not to related documents such as copies of internal correspondence about an incident to which the camera images relate. In addition, we may make other persons unrecognizable when providing the camera images. Incidentally, it is also possible that we have already deleted the camera images at the time of processing your request within the framework of the applied retention period. In that case, we will inform you of this and cannot provide you with a copy.
Your request must include the date and approximate time when the images were recorded and the location of the CCTV camera, so that the image can be easily located, and your identity can be established as the person in the images. We will usually respond promptly and in any case within one month of receiving a request. However, where a request is complex or numerous, we may extend the one month to respond by a further two (2) months. We always check the identity of the individual before processing it.
IX. Questions
If you have any questions or comments about our processing of your personal data via CCTV, please contact our [Data Protection Officer (DPO) by e-mail at [email protected] ].
X. Amendements
We may change this CCTV policy from time to time, we therefore encourage you to consult it from time to time.