Rotterdam School of Management B.V. (hereinafter RSM B.V.) uses cameras and thus closed-circuit television (CCTV) as part of its policy to promote safety and protect personal and school property within the Bayle building. By applying CCTV, RSM B.V. processes personal data since it captures imagery of people in the building. Therefore, the General Data Protection Regulation (GDPR) applies to the usage of cameras. This policy provides the framework within which CCTV capturing takes place within RSM B.V., to ensure integrity, judiciousness, and effectiveness in the application of this policy.
This policy applies to all RSM B.V. personnel in the use of authorized security cameras and their video monitoring and recording systems. Security cameras may be installed in situations and placed where the security of either people or property would be enhanced. Cameras will be limited to uses that do not violate the reasonable expectation of privacy. When appropriate, the cameras may be placed inside and outside the Bayle building. Within RSM B.V., in principle no covert cameras will be used, unless there is a legitimate interest to do so and there are no other measures that may help to solve the issue.
Within this policy, the following terms are capitalized. The following definitions apply:
Board of Directors | The full board of executive and non-executive statutory directors of RSM B.V.; |
CCTV | Closed-circuit television: surveillance using cameras; |
Data Subject | Theperson of whom Personal Datais processed. In the context of RSM B.V., this could be employees, clients, or visitors; |
Designated Observer | The ED or a staff member of RSM BV designated by the ED to perform TRA. |
ED | Executive Director: Member of the Board of Directors,responsible for alldepartments |
GDPR | The GeneralData Protection Regulation (EU 2016/679); |
Personal Data | Any information relating to an identified or identifiable natural person; |
Processing | Anyoperation or setof operations whichis performed on personal data or on sets of personal data, whether or not by automated means; |
RSM B.V. | Rotterdam Schoolof Management B.V.; |
Second-Pair-of-Eyes | A staff Member of RSM B.V.’s Privacy, Legal or HR department that is not of the same department as the Designated Observer. |
System Administrator | Astaff Member of RSM B.V. possessing extensive rights in IT systems in connection withtheir administrative dutiesand their position; |
TRA | Targeted Recording Access: The act of accessing the Video Recordings to investigate an incident and/orunpermitted behaviour; which is considered the processing of personal data. |
Video Recordings | Theresult of CCTV,the actual storedrecorded imagery, whichmay include Personal Data; |
Written/in Writing | Inthe form of a letteror a document, or by other digitalmeans of communication (in accordance with article 6:227aof Dutch Civil Law). |
The room in which the CCTV is recorded and in which TRA can take place, is accessible to authorized personnel 24 hours a day, and is protected against intrusion and vandalism.
This policy will be published on the RSM website.
The RSM B.V. Employee Council has the right of approval with regards to this policy.