UPMC Hillman Cancer Center San Pietro FBF Video Surveillance Extended Information Note

INFORMATION NOTE PURSUANT TO ART. 13 OF EU REGULATION 2016/679 ("REGULATION")

Dear Sir,
Dear Madam,

pursuant to art. 13, EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 ("Regulation") UPMC Italy with registered office in Discesa dei Giudici 4, 90133 Palermo, Italy (hereinafter, "UPMCI" or "data controller"), in its capacity of data controller hereby informs you that at UPMC Hillman Cancer Center San Pietro FBF Advanced Radiotherapy Center with registered office in Via Cassia 600, Rome, a video surveillance system has been installed (hereinafter, respectively, "Center" and "System").

The System was installed in order to prevent acts of violence to the detriment of health workers (Recommendation no. 8 of the Ministry of Health of November 2008), and to ensure the safety of employees and all people accessing its premises, and of the assets in the aforementioned Center and facilitate the exercise of UPMCI's right of defense. The system is active 24/7 inside the Center. Areas equipped with surveillance cameras are indicated with a specific sign. A map of all surveillance cameras is available at the front desk.

Images are stored for a maximum of 48 hours.  This can be extended to 72 hours during holidays and weekends, except in the case of specific investigations requested by the judicial authority or judicial police or should the storage be necessary for the protection of its interests. After these storage periods, images are recorded over previous images.

Data processing using the System does not require data subjects’ consent, as it takes place in accordance with the provisions of the Guidelines 3/2019 of the European Data Protection Board (EDPB) through video devices, and is in the legitimate interest of the data controller under art. 6.1(f) of the Regulation.

Only appointed staff may access recorded images, and exclusively in one of the following cases:

• In the event of a suspected or committed offense;
• in the event of system maintenance;
• if a data subject has requested to access them;
• upon request from the competent judicial authority or judicial police.

The updated list of person who have access to the images is available from the Internal reference person for data processing, Ms. Elena Cino, at ecino@upmc.it or to Via Cassia 600, 00189 Rome. Recorded images will not be disseminated to third parties.

The data controller is UPMC Italy with registered office in Discesa dei Giudici 4, 90133, Palermo, Italy.

The DPO at UPMCI can be reached at: UPMC Italy S.r.l. - Responsabile della Protezione dei dati, Via Discesa dei Giudici n. 4, 90133 Palermo; e-mail: DPO@upmcsanpietro.it.

As a data subject, you have the right to obtain from the data controller authorization to access, rectify or delete, and to limit or deny the processing of your personal data (art. 15 et seq., Regulation). For further information, please refer to the Italian Data Protection Authority [Garante] website https://www.garanteprivacy.it/documents/10160/0/Conosci+i+principali+diritti+previsti+dal+Regolamento+UE+2016+679. The request must be filed to the UPMCI DPO (UPMC Italy S.r.l. - Responsabile della Protezione dei dati, Discesa dei Giudici 4, 90133 Palermo; email:DPO@upmcsanpietro.it). A form to exercise the rights is available on the Italian Data Protection Authority website https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924.

Should you deem your personal data has been processed in breach of the Regulation, you have the right to file a complaint to the Italian Personal Data Protection Authority ("Garante") pursuant to art. 77 of the Regulation.

Last update: August 2022