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Information on the implementation of video surveillance in Primat d.d.

1. Contact information of the data controller

PRIMAT d.d., Industrijska ulica 22, 2000 Maribor, Slovenia
Phone: 02 250 76 00
Email: info@primat.si


2. Purposes for which personal data is processed

The processing of personal data through the use of a video surveillance system is carried out with the aim of ensuring an optimal level of protection for people and property within the controlled area of the data controller.

The data controller conducts video surveillance for the following reasons:

  • ensuring the protection and safety of employees and visitors, as well as the property of the data controller, in the area in front of and around the controller's building, including the parking lot,
  • protection and safety of employees and visitors, as well as the property of the data controller, in specific, pre-defined areas within the controller's building,
  • monitoring the entry and exit from the controller's building, including overseeing proper recording of entries and exits for employees, and
  • ensuring compliance.


3. Legal basis for the processing of personal data

Article 6(1)(f) of the General Data Protection Regulation (GDPR) in connection with Articles 76, 77, and 78 of the Slovenian Personal Data Protection Act (ZVOP-2).


4. Legitimate interests pursued by the data controller

The data controller processes personal data in pursuit of its legitimate interest, namely ensuring an optimal level of protection for people and property.

The data controller has conducted an assessment of the necessity for video surveillance, taking into account the demonstrated risk of theft of the products manufactured by the controller, the need to establish controlled entry and exit points in the production, storage, and administrative areas in accordance with good manufacturing and distribution practices, and for the purpose of protecting the company's trade secrets. The conclusion was that implementing video surveillance is essential for safeguarding the property and trade secrets of the data controller, as well as the interests of third parties who are end users of the controller’s products. These objectives cannot be achieved by less intrusive means. The processing of personal data is necessary to achieve this legitimate interest of the controller and will significantly contribute to the goals for which the video surveillance is implemented. The legitimate interest of the data controller does not override the interests or fundamental rights and freedoms of the individuals whose data is being processed.


5. Retention period

To achieve the purpose of video surveillance, a minimum retention period of fourteen days from the recording date is established. Video recordings are stored in accordance with the company's Video Surveillance Policy and Personal Data Protection Policy, or for a shorter period if prescribed by applicable legislation. After this period, the data controller ensures the permanent deletion of the recordings.

Copies of parts of recordings made and used for the purposes of asserting, exercising, or defending legal claims are retained for as long as those purposes are being pursued or until the conclusion of the legal proceedings in which the claims are asserted, exercised, or defended. If such proceedings do not occur, the recordings will be retained for no longer than the applicable statute of limitations.


6. Recipients or categories of recipients of personal data

The data controller may transfer personal data obtained through video surveillance to the following:

  • other companies, if and to the extent that such a transfer is necessary to achieve the aforementioned purposes,
  • data processors who act only according to the documented instructions of the data controller,
  • other individuals or entities, if there is a proper legal basis for the transfer,
  • the police, if legally permitted and necessary for the execution of their powers.


7. Information on specific impacts of processing, particularly further processing

The data controller will process video recordings exclusively for the primary purpose for which the video surveillance was established. However, recordings may be used as evidence in cases of deviant events (e.g., damage to persons or property) and may be used to assert, exercise, or defend legal claims related to such events.


8. Unusual further processing

Data transfers to third countries:

The data controller does not transfer personal data related to video surveillance to a third country.

If the data controller were to transfer personal data to a third country, it would be done in compliance with all conditions set by applicable regulations and provided that appropriate protective measures are implemented for the transfer, such as standard contractual clauses. Individuals may request additional information and copies of the protective measures taken in this regard.

Live monitoring:

The video surveillance system may operate in a manner that includes recording and archiving footage as well as live monitoring of events. The video feeds from individual cameras can be monitored on a screen by a security guard or receptionist who is specifically authorized for this purpose during physical security operations.


9. Rights of the individual

An individual to whom personal data pertains is guaranteed all rights related to the processing of personal data as specified in the General Data Protection Regulation (GDPR) and the Slovenian Personal Data Protection Act (ZVOP-2):

  • the right to information and access to personal data,
  • where appropriate, the right to rectification, erasure, restriction of processing, data portability, objection, and the right not to be subject to a decision based solely on automated processing.

An individual has the right to request access to personal data (recording) only in the relevant part where they appear in the footage. For this purpose, the request must specify the location where the individual was allegedly present, the date, and the most precisely defined time period, along with a reference photo (or a description of their appearance, clothing, etc.). When submitting the request, the individual must also properly identify themselves. The data controller will grant access to personal data if the individual can be identified without disproportionate effort and cost. The data controller provides copies of the requested data free of charge; however, for repeated or unfounded requests, they may charge for the material costs of providing the information.

The individual can address their request to the data controller via mail or the email address provided in point 1 (Contact Information of the Data Controller).

If an individual believes that the data controller has violated their rights regarding personal data, they may file a complaint with the Information Commissioner (Information Commissioner, Dunajska cesta 22, 1000 Ljubljana, Slovenia, gp.ip@ip-rs.si).


10. Existence of automated decision-making / profiling

Automated decision-making and/or profiling is not carried out.
More information regarding the processing of personal data is available on the website www.primat.si

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