VIDEO SURVEILLANCE POLICY OF GOLF CENTER LLC
Video surveillance policy of Golf Center LLC
1. GENERAL PROVISIONS
1.1. The Video Surveillance Policy (hereinafter referred to as the Policy) was developed to explain to subjects of personal data the purposes of processing their images caught on the video surveillance camera(s) in the territories of the Golf Center LLC organization (hereinafter referred to as the Organization) and reflects the existing In connection with this, subjects of personal data have rights and a mechanism for their implementation.
1.2. The policy establishes the procedure for conducting video control in the territories of the Organization and establishes the goals and methods of its implementation, the procedure for implementation, access to video recordings, their storage and destruction, as well as bringing to responsibility.
1.3. Based on the twentieth paragraph of Article 6 of the Law of the Republic of Belarus dated May 7, 2021 No. 99-Z “On the Protection of Personal Data” (hereinafter referred to as the Law), in accordance with the Decree of the President of the Republic of Belarus dated November 28, 2013 No. 527 “On issues of creating and using a video surveillance system in the interests of ensuring public order", by Resolution of the Council of Ministers of the Republic of Belarus dated December 30, 2013 No. 1164 "On the criteria for classifying objects as subject to mandatory equipment with a video surveillance system for the state of public safety", Law of the Republic of Belarus dated 8 November 2006 No. 175-Z “On security activities in the Republic of Belarus”, video surveillance is carried out at all facilities of the Organization in the interests of ensuring public order, including the prevention, detection and suppression of offenses, for the protection of individuals (visitors, employees), facilities Organization, including material assets and other property, control of visitor access to the Organization’s facilities, ensuring production, technological, performance and labor discipline.
1.4. The organization carries out video surveillance with the involvement of authorized persons who provide information and technological support and setup of the video surveillance system.
1.5. Authorized persons process personal data on the basis of an agreement concluded with the Organization on the processing of personal data and undertake to comply with the principles, rules for the processing and protection of personal data provided for by the Law. The agreement on the processing of personal data determines the list of actions with personal data that will be performed by the authorized person processing personal data, the purposes of processing, establishes the obligation of the authorized person to maintain confidentiality and ensure the security of personal data during their processing, indicates the necessary measures and requirements for the protection of the processed personal data in accordance with the Law.
1.6. This Policy is valid from the moment of its approval.
2. PROCEDURE FOR ORGANIZING A VIDEO SURVEILLANCE SYSTEM
2.1. At the Organization’s facilities, video surveillance is carried out around the clock and continuously using open video surveillance cameras using the “motion-based” recording function.
2.2. The Organization informs subjects of personal data about the implementation of video surveillance by placing special warning signs at the entrance group of the Organization's facilities, inside the premises of the Organization's facilities where video surveillance is carried out.
2.3. The organization does not use the video surveillance system for:
- accounting of working hours worked by employees of the Organization;
- collection of information about a specific subject;
- unique identification of persons depicted in the video;
- sound recording;
- control of premises intended for rest, eating, in clothing storage rooms (dressing room).
2.4. Video recordings cannot be used by employees of the Organization for personal or other purposes not related to the performance of official duties, and are not subject to modification, use, distribution or provision, except as provided for by legislative acts.
2.5. CCTV cameras at the Organization's facilities are installed in open and closed public areas:
| Objects | Installation locations | Video storage period |
| Retail facilities | Street parking, entrance area, sales area, warehouse premises, server rooms, administrative premises, security premises, in inventory counting areas, in cash storage areas (safe areas), in loading and unloading areas (ramp), corridors. | Not less than 30 days and not more than 31 days |
| Office rooms | Street parking, entrance area, stairwells, director's reception area, server rooms, open work areas, corridors. | Not less than 30 days and not more than 60 days |
| Warehouses | The perimeter of the building, street parking, entrance area, server rooms, administrative premises, in inventory counting areas, in loading and unloading areas (ramp), corridors. | Not less than 30 days not more than 90 days |
2.6. The storage period for video recordings at the Organization’s facilities ranges from 30 to 90 days (depending on the location of the CCTV cameras), after the specified period they are automatically deleted.
2.7. Upon receipt of information about the possible recording by CCTV cameras of situations that have signs of a disciplinary offense, an administrative offense, a criminal offense, on an oral order from the director of the enterprise, the head of the security service, the head of the internal control department, the manager for internal control over the processing of personal data, the leading security specialist information (persons performing their duties) for such video recordings, the storage period may be extended for the period of relevant events provided for by the legislation of the Republic of Belarus.
2.8. Information recorded by the video surveillance system at the Organization's facilities may be provided to government agencies and other government organizations only upon written requests in cases provided for by current legislation.
2.9. The organization has the right to use CCTV recordings as evidence in civil, criminal, and administrative proceedings to confirm the fact(s) of an unlawful act, as well as to establish other circumstances to be proven.
2.10. The access rights of employees to video surveillance systems in the Organization are established in accordance with their job responsibilities.
3. RIGHTS OF THE SUBJECT OF PERSONAL DATA
| No. | Right | Content | Consequence |
| 1 | The right of the subject to receive information regarding the processing of personal data |
The subject of personal data has the right to receive information regarding the processing
of his
personal
data in the Organization, containing:
|
The organization, within 5 working days after receiving the application, will provide the requested information to the subject or notify the reasons for refusing to provide it. |
| 2 | The right of the subject to receive information about the provision of personal data to third parties | The subject of personal data has the right to receive from the Organization information about the provision of his personal data to third parties once a calendar year free of charge. | The organization, within 15 calendar days from the date of receipt of the request, will provide information about what personal data was provided and to whom during the year preceding the date of submission of the application, or notify of the reasons for refusing to provide it. |
| 3 | The right of the subject to appeal against actions (inaction) and decisions of the Organization related to the processing of personal data | If the subject of personal data considers that the processing of his personal data is carried out in violation of the legislation of the Republic of Belarus, then the subject of personal data may file a complaint with the National Center for Personal Data Protection. | The complaint is considered in the manner established by the legislation of the Republic of Belarus on appeals from citizens and legal entities. |
3.1. To exercise one or more rights indicated under No. 1–2 of the above table, it is necessary to send the Organization a corresponding application in one of the following ways: in writing to the address: Republic of Belarus, 223053, Minsk region, Minsk district, Borovaya village, .7, room 6; in the form of an electronic document containing an electronic digital signature of the subject of personal data, to the email address info@golfminsk.by
3.2. An application for the exercise of one or more of the above rights must contain: last name, first name, patronymic (if any);
- date of birth of the subject of personal data;
- address of his place of residence (place of stay);
- statement of the essence of the requirements;
- personal signature or electronic digital signature of the subject of personal data.
3.3. The organization has the right, at its discretion, to unilaterally change and (or) supplement the terms of this Policy without prior notice to the subjects of personal data by posting it in the public domain on the Internet information and telecommunications network on the website golfminsk.com, as well as placement in free access in retail stores and other facilities of the Organization.
3.4. Issues related to the processing of personal data not addressed in this Policy are regulated by the legislation of the Republic of Belarus.
