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Processing of personal data

The operator of personal data – MAIRON GALATI SA

CUI – RO6581999

Nr. Reg. – J17 / 3127/1994

Headquarters – Belt Road, no. 59, Galați, Romania

Data Protection Officer (PDO) – privacy@mairon.ro

Section – Video Surveillance Information

Video recordings will include

  •   The physical appearance of a person
  •  The presence of the person in a certain place at a certain date and time
  •   The interaction of the person with other persons, objects, equipment, animals

Provenance of Personal Data

 They come from video recordings made by surveillance cameras

Processing purposes


  • Ensuring, organizing and executing the safeguarding of the objectives, assets, values ​​and protection of individuals
  • Ensuring the security measures of the network made up of subunits or work points distributed territorially by the management of the central unit
  • Imposing the rules regarding access and circulation within the guarded objective
  • Implementation of the necessary and applicable measures, including both the condition type elements and the elements not imposed by the minimum requirements (but which must be analyzed), in order to classify the security risks at acceptable levels, below the critical threshold.
  • Fulfillment of the legal obligation of the company to carry out the implementation of the measures established by the experts enrolled in the R.N.E.R.S.F. through the Risk analysis on the physical security of the unit
  • Monitoring of alarm systems, electronic equipment and mechanical protection equipment against unauthorized interventions
  • Increased sense of security

Necessary for the internal functionality of the company

  • Assessment of the fulfillment of the obligation of the employees to carry out the work norm or, as the case may be, to fulfill their attributions according to the job descriptions o Respect the labor discipline
  • Respect the provisions contained in the Internal Regulations, in the applicable Collective Labor Agreement, as well as in the Individual Labor Contract
  • Acting faithfully towards the employer in the performance of the duties o Respect the measures of Safety and Health at work in the unit o The obligation to respect the secret of the service
  • Executes the mandatory provisions issued by the employer, subject to their legality
  • Exercising the right of the employer to
  • Establish the organization and functioning of the unit
  • Exercise control over the performance of service tasks
  • To ascertain the perpetration of the disciplinary deviations and to apply the corresponding sanctions, according to the law

The Collective Labor Agreement applicable and the Internal Regulations o Evaluate the extent to which an employee has achieved the individual performance objectives

  • Recover the value of material damage caused by the employee due to his work
  • Ensuring the right to equal opportunities and treatment and discouraging and sanctioning any direct or indirect discrimination against an employee
  • Prevention and disciplinary sanction of employees who violate the personal dignity of other employees by creating degrading, intimidating, hostile, humiliating or offensive means, by discriminatory actions
  • Implementation of the action plan (regarding the principle of equal opportunities between women and men) aimed at preventing and combating harassment in the workplace
  • Fulfill the obligation of the employer to organize it and take all necessary measures to ensure the safety and health of employees in all aspects of work
  • Perform the permanent control of the state of the materials, equipment and substances used in the work process, in order to ensure the health and safety of the employees
  • Implement internal policies in the field of labor relations that aim
    • Elimination of tolerance for workplace bullying
    • Taking preventive and proactive anti-harassment measures
    • Preliminary measures regarding the resolution of complaints at the level of the employer
    • Ways of solving the complaints at the level of the employer
  • Providing information to the crews / intervention groups in case of accidents at work, fires, special situations and other cases of imminent danger based on the obligation of the employer to respond in order to ensure the conditions of first aid, creating the conditions of fire prevention, as well as for the evacuation of employees
  • Probation of the unexcused absences of the employee
  • Remote monitoring of operating status and record of equipment and machinery performance (legitimate interest)
  • Implementation of technical and organizational measures to guarantee and be able to demonstrate that personal data processing activities are carried out in accordance with the GDPR
  • Optimization of costs regarding security and other monitoring activities that would require (to achieve the same result) the hiring of additional personnel (legitimate interest)
  • Fulfillment of the legal obligation regarding the conditioning of the framing of information as trade secrets, of the implementation of reasonable measures to keep them secret (legitimate interest)
  • Realization of video conferences (in the case of technically equipped rooms for video conferences; within a video conference, audio / video can be transmitted / recorded) (legitimate interest)

Interactions with third parties

  • Establishment of liability for damage caused by things, ruin of the edifice or animals (legitimate interest)
  • Obtaining discounts on offers of insurance premiums for real estate and merchandise (legitimate interest)
  • Legal basis
  • The processing is necessary in order to fulfill a legal obligation of the GDPR Operator (45), art. 6 (1) c)
  • Law 333/2003 on the protection of the objectives, assets, values ​​and protection of persons Hot. Government 301/2012 for the approval of the Methodological Norms for the application of Law no. 333/2003 o Instructions M.A.I. 9/2013 regarding the carrying out of risk analyzes on the physical security of the units that are the object of Law no. 333/2003
  • Law 202/2002 on equal opportunities and treatment between women and men
  • Standard – Hot. Government 262/2019 for the approval of the Methodological Norms for applying the provisions of Law no. 202/2002
  • Contractual Law 53/2003 – Labor Code
  • Interest o Law 287/2009 – Civil Code
  • Directive (EU) 2016/943 on the protection of know-how and undisclosed business information (trade secrets) against illegal acquisition, use and disclosure


  • Dispatch company and surveillance center
  • Public servants, lawyers, magistrates, court executives – in the case of crimes, contraventions or disputes

Criteria used to determine the record storage period

  • The legality of the processing is ensured not only on the basis of the GDPR art. 22 (7) (of legitimate interests) but also based on the GDPR art. 22 (2) (necessary for the performance of a contract) and (4) (necessary for the fulfillment of a legal obligation)
    • The same recording made by a camcorder can capture personal data that is for different processing purposes.
    • There is no technical means by which the information recorded in a video frame can be automatically fragmented and stored separately according to the purpose of the processing.
  • Record storage is done on digital storage media that automatically overwrites new information over the oldest
  •  Maximum storage period varies: it is technically determined by the frequency with which each camera triggers the recording process; the degree of compression of each frame according to the encoding algorithm and the image characteristics; and the total capacity allocated to the surveillance system on storage media

Rights of the data subject

The GDPR stipulates that the data subject has the right to request the Operator (only regarding his Personal Data) the following • Access to the DCP

  • DCP rectification
  • Delete DCP
  • Restriction of processing
  • The right to oppose processing
  • Right to DCP portability
  • The right to lodge a complaint with a Supervisory Authority

About the existence of an automatic decision-making process

  • The processing does NOT include an automatic decision-making process, the surveillance system does not have the capacity for face recognition and automatic association of a registration with a data subject.
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