Overview of the group’s video surveillance system

Through the video surveillance system, data is processed for the following purposes:

1.1. the protection and monitoring of immovables and movables owned and used by the group, as well as the protection of individuals and their property;

1.2. to identify offences and to determine the party causing the damage in the case of property damage, to prevent unauthorised access, and, if necessary, to support the investigation of incidents;

1.3. to monitor production processes and equipment to ensure business continuity;

1.4. to respond to hazardous situations, ie, to take operational action to ensure compliance with safety and security requirements (eg, in the event of a fire).

The group has set the objective that the locations and placement of video cameras are chosen in such a way that they do not monitor public areas outside the group’s administrative premises, including parking areas. The locations of cameras installed in buildings are selected in such a way that they do not monitor private or recreational areas.

2.1. The legal basis for using the video surveillance system is legitimate interest (GDPR Article 6(1)(f)).

2.2. The features of the video surveillance system: stationary, mobile, digital, with logging functionality, zoom capability, vehicle number plate recognition functionality, temperature measurement functionality, and no use of audio recording.

2.3. Monitoring method – with recording and playback functionality.

2.4. Monitoring time – 24 hours.

2.5. Access and viewing rights to recordings – individuals responsible for security and the safe operation of production processes; individuals providing installation and maintenance services for video surveillance systems.

2.6. Processed personal data: the image of an individual (employees, clients, visitors, employees of partner companies and other persons) and all other activities and data recorded on the video surveillance system’s video recordings.

2.7. Retention of recordings – recordings are generally retained for 31 calendar days. After that, the data will be deleted automatically.

2.8. Security – we are committed to protecting the security of personal data processing. Therefore, we use various security technologies and procedures that help us protect personal data against unauthorised access and/or disclosure. We store data in systems to which access is restricted.

If you have any questions regarding the data processing activities carried out by us, you may contact us with requests, clarifying questions, or to exercise your data subject rights using the contact details provided in section 5 of this overview document. Pursuant to Article 12 of the GDPR, we will respond to you no later than 1 (one) month after receiving your request, and this period may be extended by up to 2 (two) months if necessary. When submitting a request, the data subject must provide information to verify their identity and specify the time period during which they were recorded, so that the group can distinguish the requesting data subject from other data subjects.

In connection with video surveillance processing operations, you have the right to obtain confirmation of whether your personal data is being processed or not. The data subject has the right to access the data and information, regarding which the group may also apply restrictions pursuant to legislation (in cases where it infringes upon the rights and freedoms of other data subjects included in the material; if the data subject cannot be identified; or in the case of excessive requests from the data subject). Where appropriate, the data subject may exercise their right to have data erased (in cases where one of the circumstances listed in Article 17(1) of the GDPR applies, and none of the exceptions listed in Article 17(3) of the GDPR is applicable) and may object to the processing.

If the data subject believes that their rights have been violated, they have the right to seek protection of their rights in court and/or lodge a complaint with the supervisory authority (in Estonia, the Data Protection Inspectorate, www.aki.ee). 

As a general rule, the Group does not issue video surveillance system recordings to external third parties who have no basis for viewing the video recordings. We issue recordings only if an authorised person requests them from us or if we have the authorised person’s permission to lawfully share the recording with a third party.

In exceptional cases, the person responsible for security may, without notifying the data subject, transmit camera recording data to law enforcement bodies in the context of offence proceedings, investigations or other similar activities (also, for example, to the prosecutor’s office, court, etc.). In the case of insured events, recordings may be shared with insurance companies.

This description, ‘Overview of the group’s video surveillance system’, outlines the concept of the video surveillance system within the Eesti Energia AS Group. If you have any questions regarding the data processing activities carried out by us, you can contact us with requests, clarifying questions, or to exercise your data subject rights using the following contact details.

Inquiries related to video recordings: [email protected]

Data protection officer contact: [email protected]

Elektrilevi AS data protection officer contact: [email protected]

Inquiries related to video recordings: [email protected]

Inquiries related to video recordings: [email protected] 

Inquiries related to video recordings: [email protected]