Information regarding the processing of personal data through a closed video surveillance circuit

We would like to inform you in the premises of the Dialysis Centers Mesogeios & Medialyse there is a closed video surveillance circuit (CCTV), through which the images of patients, visitors and employees in the public spaces of the centers are recorded. The recording takes place in accordance with the relevant provisions under the legislation in force.

1. CONTROLLER – CONTACT DETAILS
Mediterranean Center for Kidney Dialysis Holidays S.A. (business name: MESOGEIOS S.A.)
(hereunder Group “Dialysis Centers Mesogeios”)
Address: Kalessa, Gazi, Heraklion-Crete, P.C. 714 14
Telephone: +302810371560
E-mail: info@mesogeios.gr

2. DATA PROTECTION OFFICER
For issues concerning the process and in general the handling of personal data you may contact the Data Protection Officer (DPO) of the Group, Mrs Ioanna Gallou, email: dpo@mesogeios.gr

3. PURPOSE AND LEGAL BASIS OF THE PROCESSING
We use a video surveillance system with the aim to the security and protection of individuals and goods.

The legal basis of the specific processing is the protection of the legitimate interests of the Group and of the Centers, in accordance with article 6, par. 1 f., of the General Regulation for the Protection of Personal Data (EE) 2016/679.

Legitimate interest means the protection of the places and of the goods within the premises, from illegal acts, such as theft or unprovoked disaster. Moreover, we ought to ensure the safety of life, physical integrity, health and property of the employees, the patients and the visitors of the Centers.

Only image data from the public spaces of the Centers are collected, without any excessive infringement of privacy.

4. RECIPIENTS OF PERSONAL DATA
The data that are collected through the operation of the video surveillance system are kept in an electronic file, which is located in a special place of each Center and which can be accessed only by our designated personnel. This material is not forwarded to a third party, with the following exceptions: a) the competent judicial, prosecution and police authorities when it includes data essential for the investigation of an offence, which concerns individuals or goods of the DPO, b) the competent judicial, prosecution and police authorities when they legally request data, while performing their duties, and c) the victim or the offender of an offence, when it concerns data that may constitute evidence of the offence.

5. RETENTION PERIOD OF THE DATA
The data that are recorded in the system are kept for 15 working days, after which they are automatically deleted and their recovery is impossible. If we realize an illegal incident, we will keep the specific recording in a separate file for 1 month, with the aim to its investigation and the initiation of legal procedures for the defence of our legitimate interest. In case the incidence concerns a third party, we can keep the specific recording in a separate file for 3 months.

6. RIGHTS OF THE SUBJECTS IN RELATION TO THEIR PERSONAL DATA
In relation to the processing of your personal data, you can exercise the following rights:

  • Access right
    You have the right to find out if we process your image and to receive a copy.
  • Deletion right (“derecho al olvido” or “right to be forgotten”)
    You have the right to ask for the deletion of your personal data.
  • Right for the limitation of the processing
    You have the right to ask for the limitation of the processing of your personal data:
    - when their accuracy is questioned and until the respective verification takes place.
    - alternatively, instead of their deletion
    - when they are no longer essential for the purpose of processing for which they were collected, they are, however, essential for the foundation, exercise or support of legal claims on your side
    - when you object to their processing and until it is verified that there are legal reasons for this processing by the Laboratory.
  • Right to object to the processing
    You have the right to object to the processing of your personal data when this takes place on the basis of a legitimate interest.

[It is pointed out that in typical cases of video-surveillance systems, access, limitation, objection and deletion rights apply, while in extraordinary cases the other rights of the subjects of the data may apply as well.

For the exercise of the aforementioned rights and for any other queries, complaint or other information concerning the processing of your personal data, you may contact us at dpo@mesogeios.gr or at the contact details mentioned in paragraph 1.

In order for us to look at a request related to your image, you will have to specify the date as well as the place of the Center, where the recording took place concerning the exercise of your right, so that, on the one hand to facilitate the location of your data, and on the other hand to contribute to the concealing of the data of other – third parties. Alternatively, you may come to our premises so that we can show you the pictures in which you appear. We are also pointing out that the exercise of the right of objection or deletion does not entail the immediate deletion of the data or the amendment of the processing. In any case we will reply in detail the soonest possible, within the deadline laid down by the GDPR.

7. RIGHTS TO LODGE A COMPLAINT TO THE DATA PROTECTION AUTHORITY (DPA)
You have the right to lodge a complaint to the Data Protection Authority (www.dpa.gr) for issues regarding the processing of your personal data.

8. LAST UPDATE OF THE POLICY
This policy may be updated periodically.
The present last update has been in force since 09.06.2020.