Video Security System Policy - Urban Place Group
Purpose and scope of the Video Security System Policy
This Video Security System Policy (the “Policy”) has been created in accordance with the Databases Registrar’s Guideline regarding the Use of Surveillance Cameras at the Workplace and in the Framework of Employment Relations, published on October 17, 2017 and the Databases Registrar’s Guideline regarding the Use of Security and Surveillance Cameras and the Databases storing Photographs taken using such Cameras, published on October 21, 2012, both of which outline the obligations imposed on institutions with respect to the protection of the privacy interests of individuals.
The purpose of this Policy is to regulate the use of Video Security System (as defined below) deployed and operated on different venues operated by Urban Group (as defined below). Information obtained through such Video Security System will be used for security and law enforcement purposes, and for the protection of Urban Group's employees and clients as well as the general public visiting Urbans Group’s premises (the "Filmed Audience").
The following defined terms shall have the following meanings when used herein:
"Urban Group" will be deemed to include Urban Place Ltd., and any other entity under the control of, or that is otherwise related to, Urban Place Ltd..
"Video Security System" means a video installation with the capacity to view and/or record Urban Group’s premises, when used for the purposes set forth in this Policy. Personal Web cameras connected to personal computers are not subject to this Policy.
Surveillance/security cameras will be used in a professional, ethical and legal manner which respects Urban Group employees, visitors and client's privacy.
Urban Group has decided to install the Video Security System after an internal comprehensive examination regarding the necessity of such installation, and after taking into account the rights, (especially the right for privacy), of the Filmed Audience.
Urban Group will uphold an individual’s reasonable expectation of privacy as defined by law, and it is Urban Group’s obligation to maintain a safe and secure environment for its employees, clients and visitors.
Only authorized personnel, as determined by Urbans Group’s management (the "Authorized Video Security Personnel"), will be permitted to access and use the Video Security System. Mr. Romain Levy and Mr. Diego Levy have been nominated by Urban Group to be in charge of the maintaining of, and the access to, the Video Security System and its video recordings.
The Video Security System are generally not used to observe employees’ or clients’ work areas, and are never used in areas where employees or clients would have an expectation of privacy, such as in restrooms.
The Video Security System is not intended to be used as a method of tracking the work habits or productivity of individual employees or clients.
Areas under Video Security System
As mentioned above, in order to protect property and to ensure the safety of Urban Group's employees and clients, the following areas are under video surveillance:
areas where sensitive information or high-value items of Urban Group are kept or where there is other property which requires enhanced protection for a very specific reason;
public areas such as shared workspaces, corridors, entrances and exits to Urban Group premises, lounge etc.
other areas which may be also captured and recorded in a residual fashion, while the above mentioned areas are being filmed.
Urban Group had invested a lot of efforts and thought in the process of installing the Video Security System and had applied in the installation the Privacy for Design perception, as instructed by the Databases Registrar.
Management and Operations of the Video Security System
The Authorized Video Security Personnel is responsible for the management of all Video Security System used at Urban Group premises. Video-surveillance recordings may only be accessed by the Authorized Video Security Personnel. Please note that the Video Security System is connected to the internet and therefore, certain data captured and stored by the Video Security System may be subject to cyber-attacks.
The Authorized Video Security Personnel generally have access to video recordings only to the extent permitted by this Policy and law. They are prohibited from duplicating images or permitting access to others to the video recordings except as specifically permitted by this Policy and by law. Notwithstanding the foregoing, Urban Group may store and use the recordings as may be required for any legal or similar proceedings including to conduct any investigation relating to either breach of any agreement entered into with Urban Group or any law provision.
The video recordings are not made directly available to Urban Group employees, clients, or the public. Except unusual events, in order to protect the Filmed Audience's right for privacy, access to information will not be permitted to the general public. In the event that a security incident occurs, employees should report the incident to Urban Group’s management. If the event occurred in an area where the Video Security System coverage is available, the Authorized Video Security Personnel manager will review the recorded video and make a determination, in consultation with Urban Group’s management, if any video relevant to the incident is available.
Any application to provide, or store video recordings for a period that exceeds the times prescribed under Section 7 of this Policy, (including application from a non-governmental legal counsel), will not be accommodated or answered. Urban Group will delete any such recordings, even if it was clarified to Urban Group that such deletion will cause damage to the applicant or any third-party, in order to comply with the provisions of the law and this Policy. Accordingly, to the extent you wish to request the storing and/or the provision of the recordings, you are requested to furnish the Authorized Video Security Personnel with either court or police directive which guides Urban Group to do so. If a crime has been committed, you are encouraged to report it to the police. It is hereby further clarified that in any event recordings will not be stored by Urban Group other than as required or described in this Policy, or as explicitly requested by the police or by court.
Type of Personal Data Collected and Purpose
Generally, it is Urban Group’s intention that all the cameras will be operated 24 hours a day, seven days a week. However, this cannot be insured and the Video Security System may suffer from malfunctions and other faults.
The Video Security System is not intended to capture (by zooming in or deliberate choice of camera angles, for example) or, in general terms, to process images (by indexing them or
establishing profiles) that may reveal “special categories of data”, namely: racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning health or sex life.
Employees, clients and visitors should be aware that the Video Security System is not being watched most of the time and therefore there should be no expectation that they are under continuous surveillance or protection when they are in the range of a camera.
Data and Access Log Storage
The video recordings are kept for a period of no longer than thirty (30) days. After that period, the video recordings are automatically erased. Subject to the terms of this Policy, images that may be used for investigation purposes or as evidence following a security incident may be retained for a longer period. A record of their retention is kept on a rigorous basis and the need for their retention is regularly reviewed. It is hereby clarified that Urban Group may, as it sees fit and in its sole discretion, store and retain the recordings for a longer period, for the purpose of conducting legal proceedings and/or investigation and/or inquiries it might choose to perform.
Urban Group is taking several measures to insure that the relevant public is kept appropriately and thoroughly informed of its video surveillance activities, such as (i) installation on its premises of information signs to inform the public of the presence of the Video Security System. Such signs are placed close to the cameras and/or to the areas under surveillance; and (ii) the publication of this Policy on Urban Group websites under the following URL: https://goo.gl/4ZoX3n. A telephone number is provided for any person wishing to obtain further information: 03-9274577.
This Policy is a part of Urbans Group’s House Rules and Regulations as determined from time to time. A copy of the House Rules and Regulations is published on Urbans Group’s website, and shall be available for inspection at Urbans Group’s offices and shall form an integral part hereof.
If you have any inquiry regarding this Policy, or if you wish to file any request to make any appeal pursuant to the provisions of this Policy or any law or regulation which relates to the matters herein, you may do so only by submitting such appeal and/or request with one of the Authorized Video Security Personnel.