Information on the processing of personal data in accordance with Art. 13 of the GDPR
1. Name and contact details of those responsible
The Kloster Eberbach Foundation
Herr Marcel Bremser
Manager Administration, The Kloster Eberbach Foundation
Telephone: +49 6723 9178 221
1. Data protection officer contact details
NOTOS Xperts GmbH
Herr Jens Engelhardt
Heidelberger Str. 6
Telephone: +49 (0) 6151 520 10 0
2. Nature of the personal data
The video cameras process image and video recordings in the form of personal data, in particular simple biometric data, such as body size and shape, skin and hair colour, and recognisability of the face. There is no audio recording.
- Duration of Video Surveillance
Video recording takes place around the clock, seven days a week (including Sundays and public holidays).
4. Purpose and legal basis of the data processing
The purpose of the video surveillance is to ensure security on the monastery grounds for our staff and visitors, as well as to protect the monastery and monastery facilities.
The monitoring is based in particular on Art. 6(1)(f) of the GDPR, for the protection of our following legitimate interests:
- Ensuring the safety of our employees
- Ensuring the safety of our visitors
- The protection of the monastery buildings and facilities from vandalism and other damage
- The protection of the monastery buildings and facilities from theft
5. Duration of Storage
The video camera recordings are stored for seven days and then automatically recorded over.
6. Forwarding of personal data
The video recordings are not passed on to third parties unless they are required in the event of the concrete suspicion of a criminal offence by the competent authorities or for evidentiary purposes and are accordingly transmitted to them.
7. Your rights
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
8.1 Right to Information
You may request confirmation from the controller as to whether personal data relating to you is being processed by us.
If there is such processing, you can request information from the controller about the following:
the purposes for which the personal data is processed;
the categories of personal data which are being processed;
the recipient or the categories of recipient to whom your personal data has been disclosed or will be disclosed;
the planned duration of storage of your personal data or, if concrete information on this is not possible, the criteria for determining the storage duration;
the existence of a right to correct or erase your personal data, a right to have processing restricted by the controller or a right to object to such processing;
the existence of a right of appeal to a supervisory authority;
all available information on the origin of the data if the personal data is not collected from the data subject;
the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information on whether personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request information about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.
8.2 Right to Correction
You have a right of rectification and/or completion vis-à-vis the controller if the personal data processed concerning you is inaccurate or incomplete. The person responsible shall make the correction without delay.
8.3 Right to restrict processing
You may request the restriction of the processing of personal data concerning you under the following conditions:
- if you contest the accuracy of the personal data concerning you for a period, which enables the controller to verify the accuracy of the personal data;
- the processing is unlawful and you decline to erase the personal data and instead request the restriction of the use of the personal data;
- the controller no longer needs the personal data for the purposes of processing, but you need it for the assertion, exercise or defence of legal claims, or
- if you have objected to the processing pursuant to Art. 21 (1) of the GDPR and it is not yet clear whether the controller's legitimate grounds override your grounds.
Where the processing of personal data relating to you has been restricted, the data may be processed, with the exception of its storage, only with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the European Union or of a Member State.
If the processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
8.4 Right to deletion
8.4.1 Duty to delete
You may request the controller to erase the personal data concerning you without delay and the controller is obliged to erase this data without delay if one of the following grounds applies:
The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
- You withdraw your consent on which the processing was based pursuant to Art. 6 (1) (a) or Art. 9 (2) (a) of the GDPR and there is no other legal basis for the processing.
- You object to the processing pursuant to Art. 21 (1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
- The personal data concerning you was processed unlawfully.
- The deletion of the personal data concerning you is necessary for compliance with a legal obligation under European Union or Member State law to which the controller is subject.
- The personal data concerning you was collected in relation to information society services offered pursuant to Art. 8 (1) of the GDPR.
8.4.2 Disclosure of Information to Third Parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, he shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers that process the personal data that you, as the data subject, have requested that they erase all links to, or copies or replications of, that personal data.
The right to deletion does not exist insofar as the processing is necessary:
- to exercise the right to freedom of expression and information;
- for compliance with a legal obligation that requires processing under European Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health pursuant to Art. 9 (2) (h) and (i) and Art. 9 (3) of the GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) of the GDPR, where the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
for the establishment, exercise or defence of legal claims.
Furthermore, the right to deletion does not exist if the personal data must be stored by the responsible party due to statutory retention obligations and periods. In such a case, the personal data shall be blocked instead of deleted.
8.5 Right to be Informed
If you have asserted the right to correction, erasure or restriction of processing against the controller, the controller is obliged to communicate this correction or erasure of the data or restriction of processing to all recipients to whom the personal data concerning you has been disclosed, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed of these recipients by the controller.
8.6 Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used, and machine-readable and interoperable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6 (1)(a) of the GDPR or Art. 9(2)(a) of the GDPR or on a contract pursuant to Art. 6 (1)(b) of the GDPR and the processing is carried out with the aid of automated processes.
In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from one controller to another controller, where this is technically feasible. The freedoms and rights of other persons must not be affected by this.
The right to data portability shall not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
8.7 The right to object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EG, to exercise your right to object by means of automated procedures using technical specifications.
8.8 Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time and without giving reasons. In the event of revocation, we will immediately delete your personal data and no longer process it. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until revocation.
8.9 Automated decision in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or in a similar fashion significantly affects you. This shall not apply if the decision
- is necessary for the conclusion or performance of a contract between you and the responsible person,
- is authorised by legislation of the European Union or the Member States to which the controller is subject and that legislation contains adequate measures to safeguard your rights and freedoms and your legitimate interests, or
- is done with your express consent.
However, these decisions shall not be based on special categories of personal data pursuant to Art. 9(1) of the GDPR, unless Art. 9(2)(a) or (g) applies and appropriate measures have been taken to protect rights and freedoms and your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard rights and freedoms, and your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
8.10 The right of appeal to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State where you have your residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 of the GDPR.
Status: 13 March 2020
The Kloster Eberbach Foundation