CCTV Policy

Purpose

The purpose of this CCTV Policy is to establish guidelines for the use of video surveillance equipment at Pandora stores in Malta, to enhance the safety and security of our premises, customers, and staff while ensuring compliance with applicable laws and regulations. 

Images recorded by CCTV are personal data, which must therefore be processed in accordance with the General Data Protection Regulation (“GDPR”) and the Data Protection Act, Chapter 586 of the Laws of Malta. The Data Controller of all personal data gathered through CCTV within Pandora stores in Malta is SF1 Clips Limited, a limited liability company incorporated under Maltese laws, bearing company registration number C104470, and having its place of business at MK Business Centre, 155A, Floor 2, Valley Road Birkirkara BKR9022, Malta (hereinafter “SF1”).

Scope

This policy applies to all staff and visitors within all Pandora stores in Malta. The legal basis for CCTV operation is to safeguard the legitimate interests of SF1, its staff and its property.

CCTV Usage

CCTV Installation and Monitoring

SF1 has installed and shall maintain CCTV cameras at strategic locations within the Pandora stores to monitor the store's interior and entrance. CCTV monitors are operated 24 hours a day and this data is continuously recorded.

Data Retention

CCTV footage will be retained for a period of 7 days, after which it will be automatically deleted, unless required for an ongoing investigation or legal purposes.

Purpose of CCTV

CCTV surveillance is primarily used for the following purposes:

·         To identify, deter, and diminish theft, burglary or undesired conduct within our stores;

·         To minimise and thwart acts of vandalism and damage to the stores, jewellery and personal belongings;

·         To ensure the safety and security of our customers; and

·         To facilitate the identification and prosecution of offenders involved in any crimes occurring within the stores.

 

Prohibited Uses

CCTV cameras shall not be used for any purpose other than those stated in this policy. 

 

Access and Data Retention

Authorised Personnel

Access to the live CCTV feed and recorded footage is restricted to authorised personnel, including designated members of staff and management.

Handling of CCTV Data

Data Security

Access to CCTV footage and data will be protected with appropriate security measures, and disclosure will be limited to authorised individuals.

Law Enforcement

If required by law enforcement agencies, SF1 may provide recorded footage and cooperate with investigations.

Notification

Signage

Clear and visible signs will be posted at entrances and within the store to inform customers and employees that CCTV surveillance is in operation.

Review and Updates

This CCTV Policy will be reviewed periodically to ensure that it remains up to date and in compliance with legal requirements. Any necessary updates or revisions will be made as needed.

Training and Awareness

Employees will be provided with training and awareness on the proper use and handling of CCTV footage/images and the importance of privacy.

Data Subject Access Request Rights

As a data subject, you have a right to make a subject access request for CCTV footage/images. You may do so by contacting us on the following email address: Nataliya.spiteri-gingell@sf1clips.com , providing the exact date and time of the visit to our premises and proof of identity.

SF1 shall endeavour to provide the footage/images as soon as possible and within a month from receipt of request. SF1 retains the right to refuse a request for a copy where such access could prejudice the detection of crime or apprehension of offenders. 

Moreover, data subjects have the right to request SF1 to erase personal data or restrict processing, object to processing and the right to data portability by contacting us on the following email address: Nataliya.spiteri-gingell@sf1clips.com 

 

Reporting Violations

Any complaints regarding the CCTV system should be made in writing and addressed to Ms. Nataliya Spiteri Gingell at the following email address: Nataliya.spiteri-gingell@sf1clips.com 

As a data subject, you also have the right to complain to the Office of the Information and Data Protection Commissioner about our processing activities, using the following contact details:

Floor 2,

Airways House,

High Street,

Sliema SLM 1549

Phone: (+356) 2328 7100

idpc.info@idpc.org.mt

 

By following this CCTV Policy, SF1 aims to provide a secure shopping environment for our customers and staff while maintaining the highest standards of ethical and legal conduct.

Effective Date: _______________