2nd Level Notification on the processing of personal data through a video surveillance system

1. Controller Details: The private company under the name «S. AND Α. MAMADAS HOTEL AND TOURIST ENTERPRISES S.A.» and the distinctive title «HOTEL PORTO» having its seat in Thessaloniki, 65 26th October Street, tel.: +30 2310 504504/ +30 2310 504500, e-mail: info@portopalace.gr.
2. Purpose of processing and legal basis: We use a surveillance system for the purpose of protecting people and assets at our hotel. The processing is necessary for the purpose of the legitimate interests that we pursue as Controller, according to Article 6 paragraph 1 (f) GDPR.
3. Analysis of legitimate interests: Our legitimate interest consists in the need to protect our premises and our goods, or the goods of our customers from illegal acts, including, for example, theft, vandalism, damage, etc. As a hotel, we have a legal obligation to protect the property of our customers (see articles 834 et seq. of the Civil Code), and the installation of a video surveillance system in our premises is aimed at this.
   In addition, there is a legitimate interest in the protection and safety of the life, physical integrity, health and property of our staff, our customers and any third party who enters our premises. For these purposes, the video surveillance system aims to protect and secure the hotel’s facilities and infrastructure critical to its operation. Please note that we only collect image data, not audio data, and we do not use cameras with rotation (pan-and-focus cameras).
   Regarding the installation of the cameras in the hotel premises, an assessment was carried out, during which the interests and fundamental rights of the data subjects and the legal interest of our hotel were weighed, limiting the placement of the cameras only to the areas and points where we assessed that there is an increased possibility of illegal acts or increased expectation of safety and protection of persons and property.
   In accordance with article 17 paragraph 1) of Directive 1/2011, the installation of cameras in our hotel is limited to the areas intended to control incoming/outgoing traffic, such as the central entrance of the hotel, the reception area, the entrances/exits of the elevators and staircases and the entrance to the parking. Also, in the money storage areas (cash registers), in the property storage areas, in the equipment facilities and in the electromechanical facilities. Also, cameras have been placed in the entrance/exit areas of the elevators on the floors, but without taking an image from the corridors of the hotel or the entrances of the individual rooms. Toilet areas and vestibules, as well as common areas (gym, swimming pool) and catering areas, such as lounge area, breakfast area, restaurant, are not videotaped. Finally, cameras have been placed on the external perimeter of the building and this to the extent necessary for security and control of the hotel’s perimeter.