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:
CCTV | Closed-circuit television: surveillance using cameras; |
Data Subject | The person of whom Personal Data is processed. In the context of RSM B.V., this could be employees, clients, or visitors; |
EDO | Executive Director Operations: Member of the Executive Board, responsible for all operations-departments: Finance, HR, ICT, Facilities, Reception & Catering; |
Executive Board | The statutory directors of RSM B.V.; |
GDPR | The General Data Protection Regulation (EU 2016/679); |
Personal Data | Any information relating to an identified or identifiable natural person; |
Processing | Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means; |
RSM B.V. | Rotterdam School of Management B.V.; |
System Administrator | A Staff Member of RSM B.V. possessing extensive rights in IT systems in connection with their administrative duties and their position; |
TRA | Targeted Recording Access: The act of accessing the Video Recordings to investigate an incident and/or unpermitted behaviour; |
Video Recordings | The result of CCTV, the actual stored recorded imagery, which may include Personal Data; |
Written/in Writing | In the form of a letter or a document, or by other digital means of communication (in accordance with article 6:227a of 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.