Information on the processing of personal data through a CCTV system
Update on 20/8/2020
Elefsina-Korinthos-Patras Motorway (Olympia Odos) is equipped with the following video surveillance systems with CCTV cameras:
- Video surveillance system for the traffic on the motorway;
- System of cameras used by the electronic toll collection system (at toll station lanes and on the toll gantries located at some interchanges of the Motorway);
- Video surveillance system for the automatic toll machines at the motorway toll stations;
- Video surveillance system at the motorway building facilities;
- Video surveillance system at the Motorists Service Stations of the motorway.
OLYMPIA ODOS S.A., 4 Rizariou St, 152 33 Chalandri, Athens, tel. 2106843041
OLYMPIA ODOS OPERATION S.A. 32 km, A-K NNR, Northern Service Road, Ano Vlychada, 19100 Megara, tel. 22960-95400
* As regards the video surveillance system at the Motorists Service Stations of the motorway, Data Controller is only OLYMPIA ODOS S.A.
* As regards the video surveillance system at the building facilities of the Motorway (operation buildings, technical bases, toll buildings, etc.), Data Controller is only OLYMPIA ODOS OPERATION S.A.
*** For the electronic toll collection’s camera system, the Data Co-controllers and in particular only for the toll infringement files kept (i.e. the passages without paying the legal toll fare) are also the locally competent Motorway Traffic Police Departments (1st Attica, Korinthia and Achaia) that have direct, parallel and independent access to the said unlawful passages in application of Article 29, para. 10 of Law 2696/1999 (Highway Code), as amended and in force, and Pres. Decree 287/2001.
2. Processing purposes - Legal grounds
We use a surveillance system with cameras on the motorway (where contractually applicable) and in our facilities to protect people and assets. The processing is required to ensure the legitimate interests we pursue as Co-controllers (Article 6, para. 1f, GDPR).
3. Analysis of the legitimate interests
Our legitimate interest consists in our need to protect the Motorway and its assets against illegal actions, such as by way of example thefts, and to fulfill our obligations arising from the Concession Agreement ratified by Law 3621/2007, as amended and in force (such as indicatively to manage the traffic, to locate toll infringers, etc.).The same applies to the safety of life, physical integrity, health and property of our personnel and third parties who are legally in the supervised area. We only collect image data and we limit the views only to areas where we consider that there is a increased risk for illegal acts, e.g. thefts, such as tolls, the entrance, exit and the perimeter of our facilities, without focusing on areas where the privacy of people photos of whom are taken is excessively limited, including their right to respect personal data.
Only our competent/authorized personnel in charge with the safety of the area can have access to the material kept. The said material is not transferred to third parties, except in the following cases: a) to competent Court, Prosecutor and Police Authorities, when it includes data necessary to investigate a criminally punishable actwhich concerns people or goods of the controller, b) to competent Court, Prosecutor and Police Authorities, when they legally require data when exercising their duties, and c) to the victim or the perpetrator of a punishable act, when these data may constitute proofs of the said act.
* Specific data concerning passages from toll lanes within the framework of Interoperability (it’s the possibility offered either to our users-subscribers to make passages using an electronic device/transponder along the network of another motorway, or to the users-subscribers of other motorways to make passages using an electronic device/transponder along the network of Olympia Odos) may be transferred also to the relevant motorway regarding the passages of its subscribers in order to prove the passage and to invoice it.
5. Storage time
The data are kept for fifteen (15) days, after the lapse of which are automatically deleted. In the event that during this period of time an incident is established, we isolate part of the video and we keep such part up to one (1) additional month, in order to investigate the incident and initiate proceedings to defend our legitimate interests, while if the incident concerns a third party, we may keep the video up to three (3) additional months.
Data from the electronic toll system (photos and videos of passages) concerning (a) toll infringements, are kept until the time limitation of the receivables, in order to claim the amounts due, (b) other passages of interest, such as those made within the context of Interoperability or from gantries at the interchanges, to calculate the distance traveled and to charge the discounted toll rate, are kept up to three (3) months. .
6. Rights of the Data Subjects
The Data Subjects have the following rights:
- Right of access: you have the right to know if we process your image and if yes, to get a copy of it.
- Right to restriction of processing: you have the right to ask us to restrict the processing, for example not to delete the data that you consider necessary for establishing, exercising or defending legal claims.
- Right to object: you have the right to object to the processing.
- Right of erasure: you have the right to request us to erase you data.
You may exercise your rights by contacting, by e-mail or by phone, Mr. Ioannis Giannakakis, lawyer, Personal Data Protection Official of Olympia Odos S.A. at email@example.com and Mr. Filippos Mitletton, lawyer, Personal Data Protection Official of Olympia Odos Operation SA at firstname.lastname@example.org or by mail at our postal address or even by submitting your request in person at our Customer Service points. To examine a request relevant to your image, you shall define approximately when you were within the range of our cameras and provide us with a photo of yours in order to facilitate the identification of your data and help us not disclose the data of third parties. Alternatively, we offer you the possibility to come to our facilities in order for us to show you the images where you appear. Moreover, we point out that the exercise of the right to object or erasure does not entail the prompt erasure of data or the modification of the processing. In any case, we will reply you in detail at our earliest convenience, within the deadlines set out in the GDPR.
7. Right to lodge a complaint
In the event that you consider that the processing of your data infringes the Regulation (EU) 2016/679, you are entitled to submit a complaint to a supervisory authority.
In Greece, competent supervisory authority is the Hellenic Data Protection Authority, 1-3 Kifissias Ave., 11523 Athens, https://www.dpa.gr/, tel. 2106475600.
More information about the personal data kept by the video-surveillance system can be found in the Privacy Notice at: https://www.olympiaodos.gr/en/privacy/