CCTV Policy

This privacy notice tells you what to expect when companies within the GCS Malta Group (namely, GCS Accounting Malta Ltd, GCS Assurance Malta Ltd, and GCS Recruitment Malta Ltd), together ‘GCS Malta’, ‘Us’ or ‘We’ collects personal information about you, in this case, static or moving imagery via CCTV or surveillance systems as you pass through the common parts of the Agora Business Centre, Valley Road, Msida, as well as GCS Malta situated on Level 2 of the Agora premises.

GCS Malta is committed to protecting your personal information, safety, and security when you use GCS Malta services. We are legally obliged to use your information in line with all applicable laws concerning the protection of personal data, including the General Data Protection Regulation (GDPR).

WHAT INFORMATION WILL WE COLLECT ABOUT YOU?

When you pass through the GCS Malta premises, we may collect static or moving imagery via CCTV or surveillance systems.

HOW WILL GCS MALTA USE THE INFORMATION IT COLLECTS ABOUT ME?

GCS Malta may use CCTV or surveillance imagery for several purposes including but not limited to the following:

• To maintain the safety and security of the GCS Malta staff and stakeholders
• For investigative purposes or as evidence to support any formal follow-up to GCS Malta incidents
• In response to a Data Subject Access Request

The lawful justification for collecting and using CCTV or surveillance imagery is that there are legitimate interests to do so. CCTV and surveillance imagery may be handled and used by the following recipients to maintain a safe, secure and efficient operation:

• GCS Malta personnel
• Police or Security services
• Other GCS Malta service providers

We will keep your information within GCS Malta and our trusted third parties except where disclosure is required by law, for example to government bodies, law enforcement agencies or in response to a Data Subject Access Request.

HOW LONG WILL GCS MALTA KEEP MY INFORMATION?

By way of general guidance, the supervisory authority advises a 7-day retention timeframe in connection with CCTV recording. Since operational activities within GCS Malta premises may be considered high risk due to client transactions and financial services, CCTV recording may need to be accessed from 14 days prior.

Therefore, under normal circumstances your information could be retained for up to 14 calendar days after which point it will be deleted. Imagery required for investigative or evidential purposes may be retained beyond 14 days and is securely disposed of upon completion and conclusion of the purpose for which it has been retained.

Imagery is retained in a secure environment and is only accessible by authorised personnel who have a legitimate reason to do so.

WHAT RIGHTS DO I HAVE OVER MY PERSONAL DATA?

Under the General Data Protection Regulation, you will have the right to, where appropriate:

• Access your personal data by making a Data Subject Access Request
• Rectification, erasure, or restriction of your information
• Object to the processing of your information

To exercise your rights please contact the GCS Malta Data Protection Officer using the following contact details:

Data Protection Officer
GCS Malta, Agora Business Centre, Level 2, Valley Road, Msida Tel: (+356) 20161010
Or email: christian.gravina@gcsmalta.com

WHAT IF I FIND YOUR RESPONSE UNSATISFACTORY?

Should you find our response unsatisfactory, you have the right to lodge a complaint with the supervisory authority – the office of the Information and Data Protection Commissionaire (IDPC).

You can find more information on the IDPC website at https://idpc.org.mt regarding the complaints process.

CHANGES TO THIS CCTV PRIVACY NOTICE

We will keep this privacy notice under regular review, and we will place any updates here. At the start of this privacy notice we will tell you when it was last updated.