Privacy centre
Privacy notice for video surveillance
1. Why and how we process your personal data
This privacy notice (the “Privacy Notice”), together with the information signs placed next to, or near the entrances to the monitored areas, describe how Mölnlycke Health Care AB, reg. No. 556547-5489, (“Mölnlycke”, “we”, “us” and “our”) will process your personal data that is collected through the video surveillance system installed at our premises.
You may contact our Data Protection Officer (DPO) directly via email at privacy@molnlycke.com, if you have any questions or concerns.
The personal data we process primarily includes images and video recordings captured by cameras. These recordings may feature your face and other identifiable characteristics, such as your movements. From these images and recordings, we can also infer your location at a given time. Below, we provide more details regarding the processing, including what personal data (hereinafter referred to as “Personal Data”) that we process and why.
What we are doing with the Personal Data:We use cameras that capture images and video recordings, which are positioned around our external perimeter and within our premises at entry and exit locations. The cameras do not capture any sound and are placed in a manner to limit the areas captured. No cameras are positioned in a way that directly monitors employees’ workspaces, and each monitored area has a visible notice about the presence of a camera. The purpose of this is to prevent offences, ensuring the safety of Mölnlycke’s personnel, premises, and property, and to establishing, exercising, or defending against legal claims. |
Categories of Personal Data: b) The date and time when the images and video recordings were captured, which may reveal your location at a given time c) Information related to your access to certain areas, such as entry and exit times d) Any reports or logs generated from the video surveillance system that document specific incidents, such as security breaches or accidents |
Legal basis:Legitimate interest where our legitimate interests are to (i) prevent offences, (ii) ensure the safety of our personnel and other individuals visiting our facilities, (iii) protect our premises and property, and where necessary in case of an incident, (iv) to establish, exercise or defend against legal claims. If we are ordered by a competent authority or court, such as the police authority, to secure and disclose images or video recordings, we will process Personal Data on the basis of our obligation to comply with such request. |
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Retention period:The Personal Data captured by the cameras is stored for a period not exceeding 14 days and are subsequently automatically deleted, unless we need to retain it for a longer period to handle a request to exercise your data protection rights, or if a certain retention period is required by a competent authority, or to establish, exercise or defend against legal claims. |
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2. How we collect your personal data
We collect Personal Data from the cameras capturing the image and video recordings/footage.
3. How we share and transfer your personal data
Recipients: We will share your Personal Data with the following recipients:
| Recipients: | Such as: |
| Public authorities, if required. | Relevant governmental authorities, such as the police authority, that have made a formal request; in this case, the disclosure of Personal Data might be necessary to fulfil a legal obligation. |
| Suppliers or vendors assisting Mölnlycke. | Our IT-service provider (the provider of the video surveillance system and storage service), however the IT-service provider will not have access to Personal Data in encrypted form. |
| Individuals’ access. | Persons appearing in images and video recordings may request to view their images, provided it doesn’t affect the privacy of others. |
Transfer: Mölnlycke will not transfer your Personal Data to countries outside the EU and the European Economic Area (“EEA”).
4. Your rights
In this section we describe your rights as a data subject. You can exercise them by contacting us, using the contact details above. Please note that not all rights listed below are absolute and there are exemptions which can be valid.
Your rights are the following:
(a)
Right of access. You have the right to obtain a confirmation as to whether or not we process your Personal Data. If that is the case, you also have the right to receive copies of the Personal Data concerning you that we process as well as additional information about the processing, such as for what purposes the processing occurs, relevant categories of Personal Data and the recipients of such Personal Data.
(b)
Right to rectification. You have the right to have you Personal Data corrected (rectified) and/or complemented if it is wrong and/or incomplete.
(c)
Right to erasure. You have the right to request that we erase your Personal Data without undue delay in the following circumstances: (i) the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you withdraw your consent on which the processing is based (if applicable) and there is no other legal ground for the processing; (iii) you object to our processing of Personal Data, and we do not have any overriding legitimate grounds for the processing; (iv) the processed Personal Data is unlawfully processed; or (v) the processed Personal Data has to be erased for compliance with legal obligations.
(d)
Right to restriction. You have the right to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data during a period enabling us to verify the accuracy of such Personal Data; (ii) the processing is unlawful, and you oppose erasure of the Personal Data and request restriction instead; (iii) the Personal Data is no longer needed for the purposes of the processing, but are necessary for you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing of the Personal Data, pending the verification whether our legitimate grounds for our processing override your interests, rights and freedoms.
(e)
Right to object. You have the general right to object to our processing of your Personal Data when it is based on our legitimate interest. If you object and we believe that we may still process your Personal Data, we must demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
(f)
Right to data portability. If your Personal Data has been provided by you and our processing of your Personal Data is based on your consent or on the performance of a contract with you, you have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format in order to transmit these to another service provider where it would be technically feasible and can be carried out by automated means.
(g)
Right to withdraw consent. When our processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. Please note that the lawfulness of any processing based on your consent before its withdrawal is not affected by the withdrawal. We will keep information regarding your withdrawal for as long as is necessary for us to ensure that all your Personal Data relating to your former consent is erased, to the applicable extent.
5. Security measures
We have taken measures to ensure that your Personal Data is handled in a safe way. For example, access to systems where Personal Data is stored is limited to our employees and service providers who require it in the course of their duties. Such parties are informed of the importance of maintaining security and confidentiality in relation to the Personal Data we process. We maintain appropriate safeguards and security standards to protect your Personal Data against unauthorized access, disclosure or misuse. We also monitor our systems to discover vulnerabilities.
6. Complaintes to the supervisory authoraty
If you believe that our processing is performed in breach of applicable data protection legislation, we encourage you in first-hand to contact us in order for us to oversee your complaints. You may at any time also file a complaint with the relevant supervisory authority in the EU member state where you are located. You can find contact details to each local supervisory authority by visiting this link.
7. Updates to this privacy notice
Mölnlycke may update this notice periodically to reflect changes in legislation or internal policies. The latest version will always be available here on our website.