VIDEO SURVEILLANCE POLICY
1. GENERAL PROVISIONS..
In compliance with the provisions of Statutory Law 1581 of 2012, its Regulatory Decree 1377 of 2013, Article 15 of the Political Constitution, and the recommendations made by the Personal Data Protection Office of the Superintendency of Industry and Commerce, CHECOREPUESTOS S.A.S. adopts this manual for the processing of personal data acquired through its closed-circuit surveillance systems.
CHECOREPUESTOS S.A.S., as the controller of personal data obtained through its video systems implemented at its facilities located in the municipality of Funza, declares that it has implemented the provisions established in this policy to process the data collected by said systems.
2. OBJECTIVE.
This manual is issued to determine the parameters under which all personal data of natural persons acquired through the video surveillance systems of CHECOREPUESTOS S.A.S. must be processed and managed. This manual constitutes the personal databases for the processing and storage procedures used.
3. PURPOSE.
This manual implements the procedures for collecting and processing personal data to ensure the control, parameterization, and traceability of video surveillance monitoring systems. The manual aims to generate an organized framework to safeguard the private, semi-private, public, and sensitive data of their owners.
4. POLICY CONSULTATION.
This policy must be presented and made available in a visible location on the official websites of CHECOREPUESTOS S.A.S. for easy consultation and access by the general public.
The set of rules governing the processing of personal data is as follows:
✓ Political Constitution, Article 15.
✓ Law 1266 of 2008.
✓ Law 1581 of 2012.
✓ Regulatory Decrees 1727 of 2009
✓ Regulatory Decrees 2952 of 2010.
✓ Regulatory Decree 1377 of 2013.
✓ Constitutional Court Rulings C-1011 of 2008 and C-748 of 2011.
In accordance with the provisions of current applicable data protection regulations, the rights of personal data subjects are as follows:
✓ Access, know, update, and rectify their personal data with CHECOREPUESTOS S.A.S., as the data controller. This right may be exercised, among others, against data that is partial, inaccurate, incomplete, fragmented, or misleading, or data whose processing is expressly prohibited or unauthorized.
✓ Request proof of the authorization granted to CHECOREPUESTOS S.A.S. for data processing, by any valid means, except in cases where authorization is not required.
✓ File complaints with the Superintendency of Industry and Commerce for violations of the provisions of Law 1581 of 2012 and other regulations that modify, supplement, or complement it, after consulting or submitting a request to CHECOREPUESTOS S.A.S.
✓ Revoke authorization and/or request the deletion of data when the processing does not respect constitutional and legal principles, rights, and guarantees.
✓ Free access to your personal data that has been processed, at least once every calendar month, and whenever there are substantial modifications to this policy that lead to new inquiries.
Estos derechos podrán ser ejercidos por:
✓ The data subject, who must sufficiently prove their identity through the various means made available by CHECOREPUESTOS S.A.S.
✓ The data subject's successors in title, who must prove such status.
✓ The data subject's representative and/or attorney-in-fact, upon proof of representation or power of attorney.
✓ Another person on behalf of or for whom the data subject has stipulated, or an unofficial agent, provided that they prove, at least summarily, their legally protectable interest.
Data processed through video surveillance systems will be preserved in compliance with all legal provisions that guarantee the privacy of such data. In this regard, the provision of such data may be restricted or limited to safeguard privacy or for security reasons.
To guarantee the privacy of the images, CHECOREPUESTOS SAS reserves the right to provide any video unless there is an order from a competent administrative or judicial authority.
8. AUTHORIZATION FOR USE OF PERSONAL DATA.
CHECOREPUESTOS S.A.S. will not request the data subjects' authorization for the processing of their personal data using video surveillance systems; however, it will process the data using unequivocal procedures in accordance with the provisions of Article 2.2.2.25.2.5 of Single Decree 1074 of 2015. The Data Subject has the right to revoke any authorization, unless there is a legal or contractual obligation that establishes otherwise. In the case of contracts with CHECOREPUESTOS S.A.S., the Data Subject's personal data is required for purposes related to the provision of the contracted services, and it will be used for these purposes.
CHECOREPUESTOS SAS, a commercial company with headquarters in San Vicente del Caguán, Caquetá, will be responsible for the processing of personal data provided and processed in accordance with the purposes that will be defined later.
The processing of personal data must be carried out in accordance with the terms and scope of the authorization granted by the data subject or pursuant to special regulations when a legal exception exists. Any request arising from the exercise of the duties and rights enshrined in this manual may be addressed to:
Email address: servicioalcliente@checorepuestos.com
Business telephone number 1: +57 601 3145010
Business telephone number 2: +57 601 3451541
11. PRIVACY NOTICE.
A privacy notice will be posted in areas near the locations where video monitoring is conducted. It will include minimal information on processing, specific purposes, and other information of interest to the data subject.
12. EVENTS AT WHICH SECURITY VIDEOS CAN BE PROVIDED.
The company guarantees the confidentiality and privacy of the data collected by its video surveillance systems, and for this reason will restrict the provision of videos to the following events:
✓ When the claimant is the data subject and the privacy of third-party data or the image rights of other people are not affected.
✓ When requesting videos to corroborate vehicle collisions, provided that the applicant can prove their status as a victim of the violation or accident.
✓ When the claimant requests the video for reasons other than a criminal offense or police violation, in these cases the videos will only be provided to the competent authority under the terms established in Article 19 c of Law 793 of 2002.
FIRST PARAGRAPH.
Before supplying any video, the company will analyze the feasibility of supplying it, for which it will have a period of ten (10) business days.
SECOND PARAGRAPH.
The company reserves the discretion to analyze the provenance and appropriateness of providing the video, and may in any case refuse to provide it when it deems it appropriate.
THIRD PARAGRAPH.
Any video containing the attempt or completion of a punishable act, police violation, or similar offense will only be provided to the relevant competent authority.
FOURTH PARAGRAPH.
In the event that the video is provided, the data subject must complete a form before it is delivered.
FIFTH PARAGRAPH.
Any video provision will depend on the availability of storage space. Therefore, the company assumes no responsibility for the deletion or failure to safeguard a copy of the video.
SIXTH PARAGRAPH.
Access to the room where the video is located is completely restricted, and no unauthorized person will be allowed access.
SEVENTH PARAGRAPH.
Taking videos of the entity's staff or facilities is not permitted.
EIGHTH PARAGRAPH.
The provision of any video will be subject to prior control by the entity, so its provision may be restricted in accordance with legal stipulations.
13. OPERATIONAL PROCEDURES INVOLVING THE PROTECTION OF PERSONAL DATA.
The data controller and/or data processor must observe the following rules:
✓ Request and retain proof of the Data Subjects' authorization for the Processing of their personal data. This will be done in the event such authorization is requested.
✓ Implement the video surveillance system only when necessary to fulfill the proposed purpose, respecting the dignity and other fundamental rights of individuals.
✓ Limit the collection of images to what is strictly necessary to fulfill the specific purpose previously conceived.
✓ Inform Data Subjects about the collection and other forms of image processing, as well as its purpose.
✓ Retain images only for the time strictly necessary to fulfill the purpose of the VIDEO SURVEILLANCE SYSTEM. For the purposes of determining the storage duration of the data acquired by this system, it will be for one month.
✓ Register the database that stores the images in the National Registry of Databases. Registration will not be required when the Processing consists solely of the reproduction or broadcasting of images in real time, without prejudice to compliance with the other provisions of the General Personal Data Protection Regulation.
✓ Sign confidentiality clauses with the personnel who will access the VIDEO SURVEILLANCE SYSTEM.
✓ Do not install the VIDEO SURVEILLANCE SYSTEM in locations where the collection of images and, in general, the Processing of this data could affect the image or the private and intimate life of individuals.
The specific purposes for processing data collected through video surveillance systems will be the following:
✓ Collect video footage of users and visitors.
✓ Implement security measures to monitor incidents.
✓ Deter irregular behavior by third parties.
✓ Control the entry of users, patients, and employees to the institution's facilities.
✓ Conduct employee termination processes for just cause, discharges, and disciplinary proceedings for employees.
15. THE POLICY FOR THE PROCESSING OF PERSONAL DATA CAPTURED BY VIDEO SURVEILLANCE SYSTEMS.
It can be requested by email or in writing.
16. DATA TRANSMISSION.
The data may be processed by a personal data processor with whom a data transmission contract has been signed in accordance with Article 25 of Decree 1377 of 2013.