Data Protection Policy concerning its Video Surveillance Systems
1. The purpose of this Policy
The purpose of this Policy is as follows: to define the legally appropriate regime and practice of operating video and sound recording systems at Pesti Vigadó Nonprofit Ltd.'s (address: H-1051 Budapest, Vigadó tér 2., Hungary; tax number: 24955461-2-41; represented by: Executive Barbara Molnárné Szunyi; hereinafter: Limited) premises, to ensure the observance of Hungarian constitutional principles concerning data protection, to guarantee adherence to the requirements of data protection, as well as to prevent unauthorised access to data generated by such video and sound recording systems, including the alteration and unauthorised disclosure of such data.
2. The scope of this Policy
The scope of this Policy extends, on the one hand, to any organisational unit and its employees involved in operating and maintaining video surveillance systems on behalf of the Limited at its premises and, on the other hand, to organisational units and their employees described and defined in this Policy.
Issues not addressed in this Policy are governed by the Limited's general data protection policies and by the pertaining laws in force on data protection. The regulations contained in the present Policy cannot be in conflict with the pertaining laws in force on data protection or with the Limited's general data protection policies.
3. Data controllers and data processors
Pesti Vigadó Nonprofit Ltd. acts as data controller. Within the organisational framework of the Limited, the operation and management of the video surveillance systems and the data recording systems as well as the actual job of data control are performed by Pesti Vigadó Nonprofit Ltd.'s Facility Management Section and by the actual data processors.
Data processors
In the scope of managing personal data, the Data Controller engages the following data processor for the purpose of monitoring any live recordings and images captured by closed-circuit television systems at the Limited's premises:
name: S-SYSTEM Service Kft.
seat: 1039 Budapest, Fodros utca 33., Hungary
contact data: titkarsag@s-system.hu
4. Video surveillance systems are operated by the Limited at the places outlined in the table below:
|
| Name and description of area |
| P/1 | Basement, ground floor exhibition hall, stairway |
| P/2 | Basement, exhibition hall |
| P/3 | Basement, service passageway |
| P/4 | Basement, exhibition hall, entrance |
| Fsz/1 | Ground floor, exhibition hall, corner of Deák Ferenc Street and Library |
| Fsz/2 | Ground floor, exhibition hall, corner of Reception Area and Library |
| Fsz/3 | Ground floor, exhibition hall, basement and Library stairway |
| Fsz/4 | Ground floor, exhibition hall, corner of Deák Ferenc Street and Arcade |
| Fsz/5 | Ground floor, exhibition hall, corner of Reception Area and Arcade |
| Fsz/6 | Ground floor, corner of Reception Area and exhibition hall |
| Fsz/7 | Ground floor, Lobby, Information Desk, north |
| Búv/1 | 2nd floor, artists' dressing rooms, corridor leading towards stairway |
| Búv/2 | Ornamental Stairs, right (hidden) |
| Búv/3 | Ornamental Stairs, middle (hidden) |
| Búv/4 | Ornamental Stairs, left (hidden) |
| Loc/1 | Ground floor, Main Entrance, south |
| Loc/2 | Ground floor, Main Entrance, north |
| Loc/3 | Ground floor, Foyer, south, middle |
| Loc/4 | Ground floor, Foyer, south |
| Loc/5 | Ground floor, Foyer, north |
| Loc/6 | Ground floor, Foyer, north, middle |
| Loc/7 | Ground floor, stairway, corridor |
| Loc/8 | Ground floor, reception area at staff entrance |
| Loc/9 | Exterior, Deák Ferenc Street, staff entrance |
| Loc/10 | Exterior, corner of Deák Ferenc Street and Arcade |
| Loc/11 | Exterior, Arcade leading towards Deák Ferenc Street |
| Loc/12 | Exterior, Arcade leading towards Main Entrance |
| Loc/13 | Exterior, Arcade, door of restaurant |
| Loc/14 | Exterior, Arcade leading towards Vigadó Street |
| Loc/15 | Exterior, corner of Vigadó Street and Arcade |
| Loc/16 | Exterior, Vigadó Street, pavement in front of Casino |
| Loc/17 | Ground floor, Lobby, Information Desk, south |
| Loc/18 | Ground floor, corner of Reception Area and Lobby |
| Loc/20 | Floor between 1st and 2nd floors, Southern Stairway, Corridor |
| Loc/19 | Floor between 1st and 2nd floors, Server Room |
| Loc/21 | 1st floor, Southern Bulk, Stairway, Corridor, Room 113 |
| Loc/22 | 1st floor, Southern Bulk, lift |
| Loc/23 | 2nd floor, Southern Bulk, lift |
| Loc/24 | 2nd floor, Foyer, south |
| Búv/5 | 5th floor, north, artists' dressing rooms, corridor |
| Búv/6 | 4th floor, north, artists' dressing rooms, corridor |
| Búv/7 | 3rd floor, north, artists' dressing rooms, corridor |
| Búv/8 | 2nd floor, north, artists' dressing rooms, corridor leading towards hall |
| Loc/25 | 2nd floor, Foyer, north |
| Loc/26 | 2nd floor, Southern Bulk, Stairway, corridor |
| Loc/27 | 3rd floor, Southern Bulk, Stairway, corridor |
| Loc/28 | 4th floor, Southern Bulk, Stairway, corridor |
| Más/1 | 2nd floor, Northern Hall, corridor |
| Más/2 | 2nd floor, Northern Hall, hallway, corner |
| Más/3 | 2nd floor, Northern Hall, artists' dressing rooms, corner |
| Más/4 | 2nd floor, Northern Hall, Foyer, corner |
| Más/5 | 2nd floor, Southern Hall, small room |
| Más/6 | 2nd floor, Panoramic Corridor, south |
| Más/7 | 2nd floor, Panoramic Corridor, north |
| Más/8 | 2nd floor, Hallway |
| Más/9 | 2nd floor, corner of Southern Hall and Ceremonial Hall |
| Más/10 | 2nd floor, corner of Southern Hall and Small Room |
| Más/11 | 2nd floor, corner of Southern Hall and Corridor |
| Más/12 | 2nd floor, corner of Southern Hall's Corridor and Hidden Service Area |
| Más/13 | 2nd floor, corner of Hidden Service Area and Southern Stairway |
| Más/14 | 2nd floor, corner of Hidden Service Area and Southern Hall |
| Más/15 | 2nd floor, VIP Box and entrance to Ceremonial Hall |
| Más/16 | 2nd floor, corner of Southern Hall's Corridor and Foyer |
| Loc/29 | 4th floor, Southern Bulk, lift |
| Loc/30 | 4th floor, Offices, corridor |
| Loc/31 | 4th floor, Secretariat |
| Loc/32 | 4th floor, corner of Makovecz Hall and Secretariat |
| Loc/33 | 4th floor, corner of Makovecz Hall and Presidential Suite |
| Loc/34 | 4th floor, Panoramic Corridor, south |
| Loc/35 | 4th floor, Panoramic Corridor, north |
| Loc/36 | 4th floor, Meeting Room, back corner |
| Loc/37 | 4th floor, corner of Meeting Room and Panoramic Corridor |
| Loc/38 | 4th floor, Sinkovics Theatre, corridor |
| Loc/39 | 4th floor, Foyer, north |
| Loc/40 | 4th floor, Foyer, north, middle |
| Loc/41 | 4th floor, Foyer, south, middle |
| Loc/42 | 4th floor, Foyer, south |
| Loc/43 | 5th floor, Southern Bulk, Stairway, corridor |
| Loc/44 | 5th floor, Southern Bulk, lift |
| Moz/9 | 4th floor, Ceremonial Hall, space facing Foyer, south |
| Moz/10 | 4th floor, Ceremonial Hall, space facing Foyer, north |
| Loc/4 táp | Ground floor, Southern Bulk, lift |
| Loc/50 táp | 5th floor, service-purpose storage room |
| Moz/1 | 4th floor, Ceremonial Hall, north, middle |
| Moz/2 | 4th floor, box with service-purpose equipment, space facing Foyer |
| Moz/3 | 4th floor, box with service-purpose equipment, space facing Panoramic Corridor |
| Moz/4 | 4th floor, Theatre, space facing hallway |
| Moz/5 | 4th floor, Theatre, space facing facade |
| Moz/6 | 4th floor, Ceremonial Hall, south, middle |
| Moz/7 | 4th floor, Ceremonial Hall, space facing Panoramic Corridor, north |
| Moz/8 | 4th floor, Ceremonial Hall, space facing Panoramic Corridor, south |
| Loc/45 | 5th floor, Foyer, north |
| Loc/46 | 5th floor, Foyer, south |
| Loc/47 | 6th floor, Foyer, south |
| Loc/48 | 6th floor, Foyer, north |
| Loc/49 | 6th floor, Southern Bulk, lift |
| Loc/50 | 5th floor, Exhibition Space A |
| Loc/K-F | 5th floor, Exhibition Space B |
| Loc/B-F | 5th floor, Exhibition Space C |
| Hat/1 | 6th floor, Panoramic Corridor, northern exit |
| Hat/2 | 6th floor, Panoramic Terrace, Corridor, panoramic stairs |
| Hat/3 | 6th floor, Panoramic Terrace, north |
| Hat/4 | 6th floor, Panoramic Terrace, south |
| Hat/5 | 6th floor, Panoramic Terrace, southern exit |
| Hat/6 | 6th floor, Room 62, Multifunctional Room A |
| Hat/7 | 6th floor, Room 62, Multifunctional Room B |
| Hat/8 | 6th floor, Room 62, Multifunctional Room C |
| Hat/9 | 6th floor, Room 61, Multifunctional Room A |
| Hat/10 | 6th floor, Room 61, Multifunctional Room B |
| Hat/11 | 6th floor, Room 61, Multifunctional Room C |
5. The purpose of data control
The purpose of operating video surveillance systems at the Limited's premises is to protect and guard persons, their lives, their personal freedom and their physical integrity, as well as to perform property protection in the scope of guarding the facilities and locations managed and/or owned by the Limited not qualifying as public places (hereinafter: protection of property and persons).
6. The scope of controlled data, the source of data and the legal basis of data control
In the scope of operating video surveillance systems at the Limited's premises, controlled data, the source of data and the legal basis of data control are described as follows:
- controlled data: the images of the persons concerned,
- the source of controlled data: the persons concerned,
- the legal basis of data control: consent by the persons concerned through exhibiting consenting behaviour.
7. Methods of data management (equipment)
Video surveillance systems operated by the Limited consist of the following: (a) cameras installed in exterior (outside Pesti Vigadó's building) and/or interior (inside Pesti Vigadó's building) spaces and intended for use in the scope of general monitoring of locations, (b) monitors displaying the images captured by cameras and (c) a central unit (DVR), located in the Limited's server room or rack cabinet, which records, in an electronic format, the images captured by the said cameras.
8. Rules governing access to data
Unless used for further purposes, recordings shall be destroyed and deleted within three working days the latest following their capture. Unless used for further purposes, recorded still or moving images shall be destroyed and deleted within four days the latest following their capture.
In the present context, "use for further purposes" shall mean the application of said recordings and images for the purpose of being used as evidence in the scope of legal proceedings or any other proceeding instituted by any public authority, or the scenario when such recordings and images have been submitted to any court or authority in the scope of such proceedings.
In line with the above, those persons whose legal rights or legal interests are impacted or influenced by such recordings or images may request – within three days following the capture of such data and upon presenting and substantiating their legal rights and legal interests to this end – the data controller of the said recordings or images to refrain from destroying and deleting such data. At the request of any court or authority, captured recordings and images shall immediately be made available to the said court or authority.
If there is no further request by any court or authority within thirty days following a prior request by any such court or authority to refrain from destroying and deleting a given set of data, all relevant captured visual and audio recordings as well as all relevant still and moving images together with any involved personal data shall ultimately be destroyed and deleted.
All captured visual and audio recordings as well as all still and moving images together with all the personal data involved shall be disclosed exclusively to those personnel involved in performing protection of property and persons who must necessarily be in possession of such information so that they can perform their contractual duties and so that any illegal activity can be prevented or discontinued by way of the disclosure of such information.
The saving and copying of such data as well as all the facts and information pertaining to data provision related to said requests shall be documented in the form of minutes (Appendix 1), which contain the following information:
- the name and address of the entity requesting the data (entity requesting data),
- the reason and purpose of saving and copying data as well as the information substantiating legal rights and legal interests supporting the request to disclose such data (request),
- data concerning the position of the video surveillance system, and the exact place of capturing the requested recording or image,
- the exact date and time as well as duration of capturing the recording or image,
- the name and employer (workplace) of the person performing the saving and copying of data.
A copy of the said minutes shall be sent to the entity requesting the saving and copying of such recording or image. Furthermore, according to the Limited's Data Protection Policy, data concerning the said copy of the minutes shall be entered in the data transfer records and a copy of the said minutes shall also be retained as an annex of the referent entry of the records.
9. Obligation to provide information concerning the operation of video surveillance systems
In the spaces monitored by its video surveillance systems, the Limited is liable to provide clear and detailed information to all those concerned with and involved in such surveillance regarding the following issues: the aim of capturing the recording or image, the legal basis of data control, the place where the captured recordings and images are stored, the storage period of the captured recordings and images, the entity managing the surveillance system (operator), the scope of persons and entities entitled to have access to such data, as well as the regulations contained in the Hungarian Act LXIII of 1992 on the protection of personal data and the publicity of data of public interest with respect to the rights and the reinforcement of the rights of all those concerned with and involved in such surveillance. This information shall also be made available on the Limited's website and shall also be made accessible to the visually impaired.
In the spaces monitored by video surveillance systems, pictograms, notice boards and stickers bearing the following text shall be posted at clearly visible places:
"The area is managed and video monitored by Pesti Vigadó Nonprofit Ltd.
The purpose of operating a video surveillance systems in this area is the following: to ensure the protection of facilities and locations managed and/or owned by Pesti Vigadó Nonprofit Ltd. not qualifying as public places; to protect and guard the life, physical integrity and property of visitors and of Pesti Vigadó Nonprofit Ltd.'s staff and agents; to prevent any terrorist attacks, acts of danger to the public and accidents; and to facilitate any subsequent investigations of minor offences and crimes that may have been committed in this area. The recordings and images captured in this area are available exclusively to courts, to authorities as well as to entities and persons legally authorised to view such recordings and images.
Those persons whose legal rights or legal interests are impacted or influenced by recordings or images captured in this area may request – within three days following the capture of such recordings or images and, in the case of public events, within thirty days following the capture – the data controller of such data to refrain from destroying and deleting such recordings or images by way of contacting Pesti Vigadó Nonprofit Ltd. (postal address: H-1051 Budapest, Vigadó tér 2., Hungary) in writing, upon presenting and substantiating their legal rights and legal interests to this end. If no request to this end arises, all related recordings and images are deleted after three or thirty days, respectively.
By being in this area, you consent to being video monitored and to having the related recordings or images transferred or made available to other parties in the scope of the above-described activities and in line with the above.
Accordingly, the legal basis of data control is constituted by the consent granted by the video monitored persons."
10. Legal remedy
In case those concerned with and involved in such surveillance perceive any infringement of their rights, they can turn to
the Limited's Executive or
file a claim in court, or alternatively
they can request the Hungarian National Authority for Data Protection and Freedom of Information (Address: H-1125 Budapest, Szilágyi Erzsébet fasor 22./C, Hungary, e-mail address: ugyfelszolgalat@naih.hu) to initiate proceedings.
11. Referent legislation
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
- Hungarian Act CXXXIII of 2005 on the rules of personal and property protection activities and private investigation activities
- Hungarian Act CXII of 2011 on the right of informational self-determination and on freedom of information
12. Miscellaneous provisions
The present information booklet enters into force on 21st May 2018 and will remain in effect until its withdrawal.
I hereby order the use of the present information booklet.
Dated: Budapest, 21st May 2018.
Dr. Molnárné Szunyi Barbara
General manager
Appendix 1 - Minutes on Data Saving and Data Provision