Privacy notice: Personal data register for access control and camera surveillance at Espoo’s self-service libraries

Date of publication: 17 September 2020

City of Espoo

firstname.lastname@espoo.fi

Miika Miettunen, Senior Library Services Manager

Mikko Hämäläinen, Library Pedagogue

P.O. Box 3605, 02070 CITY OF ESPOO

Tel. +358 9 81621 (switchboard)

tietosuoja@espoo.fi

Using the self-service library system, a Helmet library customer can unlock the door with their library card and PIN code and access the library during the designated self-service hours.

The purpose of access control and camera surveillance at self-service libraries is to maintain order and protect the premises. The systems are used to protect the libraries’ property, prevent crime and disturbances, and help investigate incidents that may occur. In addition, the systems help ensure and enhance the safety of both library customers and staff. The library card number cannot be linked to any personal data without retrieving the information from the library system using the card number. The library system is a completely separate register from this register.

Article 6(1)(c) of the General Data Protection Regulation of the European Union: Processing is necessary for compliance with a legal obligation to which the controller is subject.

• Image data recorded by the cameras that are part of the recording surveillance system at Espoo’s self-service libraries.

The register consists of three sub-registers:

1. Still images and their storage, and the storage of the library card code used for entry on the server in the ServManager database.
2. The self-service library recording device (NAS) at the library in question.
3. The self-service library log, stored in the central unit at the library in question.

PUBLIC ACCESS TO AND CONFIDENTIALITY OF DATA:

The data in the register is confidential.

GROUNDS FOR CONFIDENTIALITY:

Provisions on the confidentiality of data are laid down in section 24 of the Act on the Openness of Government Activities.

1. Images captured by the still cameras: 1–3 still images are recorded when a person enters the library using the access control reader. The library card number used is recorded at the same time.
2. Image data captured by the IP cameras that are part of the surveillance system, stored in a NAS recorder (QNAP or Axis recorders are used) located in the library in question.
3. Access control time stamps for the log.

As a rule, personal data will not be disclosed.

Any transfer or disclosure of data must be based on legislation or an order given by an authority.

Data is not transferred outside the EU or the EEA.

Register data is stored in the recording device for 28 days. Data is destroyed by overwriting it. Still images are stored on the server for 28 days, after which they are automatically erased.

Personal data is protected against unauthorised access and unlawful processing, such as loss, alteration or disclosure.

A. Electronic materials

Still images are transferred to the server using the SFTP protocol. The recording device (digital recorder) is in a locked room that can only be accessed by the library’s designated person. The recorder is password-protected and can only be accessed by the person in charge of the register or a person authorised by them.

B. Manual materials

Not stored.

Further instructions on submitting information requests referred to in the General Data Protection Regulation: Data protection / Rights of the data subject

You have the right to obtain from the data controller a copy of the personal data that is subject to processing. The data controller must provide the data without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

If the data controller does not take action on the request of the data subject, the data controller must inform the data subject without delay, and at the latest within one month of receipt of the request, of the reasons for not taking action and of the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Requests from the data subject and any resulting actions are free of charge. However, where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the data controller may either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request.

You have the right to have inaccurate, incomplete, outdated or unnecessary personal data that we store either rectified or completed by us.

You have the right to have the data controller erase your personal data without undue delay under certain conditions. The data subject does not have the right to erasure if the processing of data is necessary for compliance with a legal obligation or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller. In these cases, the data will only be erased after the statutory time limit.

If the data concerning you is inaccurate, you have the right to request that its processing be restricted until its accuracy has been verified.

You have the right to lodge a complaint with a supervisory authority if you feel that the processing of your personal data is in infringement of data protection legislation. You can lodge a complaint with the Office of the Data Protection Ombudsman: www.tietosuoja.fi(external link, opens in a new window)