Special Information from HPPC SA on the processing of personal data via video surveillance systems operating in its Business Units.

HPPC SA informs you hereby in accordance with Regulation (EU) 2016/679 (hereinafter “GKPD”), Law 4624/2019 and the other provisions of the relevant Greek and EU legislation on the protection of personal data, as in force, acting as Data Controller for the operation of video surveillance systems in its Business Units (hereinafter “Branches”), for the type of personal data it collects, the purpose of their collection and processing, the time of their storage as well as for your rights as subjects of the data. It is explicitly clarified that in the videotaped area there are special notifications (visible warning signs) that provide information at the first level to the data subjects about the processing of their data through the video surveillance systems and this constitutes the most detailed information on the second level.

What personal data does HPPC SA collect from you and from where?
HPPC SA collects the necessary image data from the video surveillance systems operating in the Branches, such as, indicatively, cash registers, safes, entrances/exits and in general in access points to individual key security areas of Branch facilities.

HPPC SA collects only image data from appropriate locations and angles of video surveillance systems in such a way as not to overly restrict the privacy of subjects being photographed, including their right for respect of personal data.

Why does HPPC SA collect your personal data and on what legal basis does it process it?
HPPC SA collects the above personal data for reasons of the protection of persons, goods and in general infrastructure located in its Branches, with a legal basis for the protection and defense of the legal interests of HPPC SA. or a third party (article 6 par. 1 of GKPD).
Who are the recipients of your personal data?
Recipients of your personal data are the competent employees of HPPC SA. within the framework of their duties, which include caring for the safety and/or performers of the processing that they monitor and/or handle on behalf of HPPC SA the video surveillance systems operating in its Branches (eg private security companies). In the event of a need to comply with a legal/regulatory obligation, an incident of an illegal act or if the need arises to defend the legal interests of HPPC SA or third parties (indicatively for the establishment, exercise or support of legal claims or evidence of a criminal offense) the recipients of your data may be, for example, lawyers, law firms, bailiffs, experts, experts, supervisors, independent, judicial, prosecutors, police, public and/or other authorities or bodies, the person portrayed as the perpetrator or victim of a criminal offense, in the case of data which may constitute evidence of that offense.
For how long does HPPC SA keep your personal data?
Your personal data is kept for a period of fifteen (15) days. If during this period cases of an illegal act are recorded, the relevant parts of the data of the video recording system maybe kept in a separate file with appropriate security measures, for as long as is required for the investigation and disciplinary or judicial prosecution of these incidents.
What are your rights and how are they exercised?
If your personal data is processed through a recording by a video surveillance system of HPPC SA, you have the following rights:

a) Ask to be informed of the categories of your personal data that we hold and process, their origin, the purposes of their processing, the categories of their recipients, the time of their holding as well as your relevant rights and request to receive a copy of them (right of access).

b) Request the restriction of the processing of your personal data (right of restriction).

c) Oppose the processing of your personal data (right to object).

d) Request the deletion of your personal data.

To exercise any of the above rights you can contact the Data Protection Officer (DPO) Ms. Marilena Bellou, postal address: Voulis 7, 10562 email: [email protected].

Please note the following in relation to your above rights:

i. HPPC SA has in any case the right to refuse your request for restriction of the processing or deletion of your personal data if the processing or keeping of the data is necessary for the establishment, exercise or support of its legal rights or the fulfillment of its obligations.

ii. The exercise of the above rights relate to the future and does not involve data processing already performed.

iii. HPPC SA has the right to ask you for additional information necessary to confirm your identity.

iv. To consider a request related to your image, you should specify in your request the place, date and time (albeit approximate) that you were within range of the video surveillance systems and provide a recent image of yourself to facilitate locating your own data and the hiding of data of depicted third parties.


Right of complaint to the HDPA

You have the right to submit a complaint to the Hellenic Data Protection Authority (