Skip to main content

      Video Surveillance Management

      (Version: 1.0 – Date: 31/08/2021 Review date: 01/01/2023)


      KPMG Luxembourg (the controller) is committed to the appropriate protection and use of your personal data to ensure that your rights and freedoms as a data subject are respected. This Fair Processing Notice describes how we will process the personal data that you will provide to us, or that we will receive from other sources, in the context of the Video Surveillance Management.

       

      The following department of KPMG Luxembourg will primarily process your personal data:

      • Facilities.

      We will process your personal data for the following purposes:

      • The processing activities consists in securing the KPMG buildings and some specific premises (such as data rooms, patching rooms, reception desk); 
      • The processing aims to ensure the safety of visitors and employees as well as to prevent attacks on property such as theft, burglaries or vandalism. Although the camera may record KPMG employees, personnel of suppliers, clients and other visitors’ actions, it is not the purpose of KPMG to monitor individuals’ behaviours nor to monitor KPMG employees’ work time or performance.
      • The processing activity allows KPMG to pinpoint the origin of an incident with precision if an internal/external investigation is required.

      We will process the following (categories of) personal data:

      • Face photographs.
      • Video footage.

      We will process the following sensitive (or special categories of) personal data:

      • Not applicable.

      If your personal data is not be collected directly from you, we will receive / retrieve it from the following indirect sources:

      • Not applicable.

      We will transfer your personal data to the following recipients:

      • Our data processor (in charge of the security of the building);
      • The authorities (if required and in compliance with applicable laws).

      We will retain your personal data for:

      • 30 days after the recording.

      Please note that:

      • Your personal data will not be subject to an automated decision-making / profiling process.
      • The legal basis for the processing of your personal data is:
        • The legitimate interest of KPMG which is to secure its assets and protect its people. The video surveillance system is the best way for KPMG to secure its assets and protect its staff. In addition, compliance with CNPD guidelines (no voice recording, blurring of images, etc.) ensures maximum protection of the privacy of the data subjects.
      • Your personal data will not be transferred outside of the EU.

      The provision of your personal data to us is

      • Mandatory.

      The consequences of not disclosing your personal data to us or not allowing us to process your personal data are as follows:

      • You will not be allowed to enter our facilities.

      You have the following rights concerning the processing of your personal data:

      • Access: you have the right to request access to your personal data. This is usually called a ‘Data Subject Access Request’. If we agree that we are legally allowed to grant you access to your personal data, we will do it free of charge. Before granting you access to your personal data, we will ask for a proof of identity. If the personal data cannot be separated from other third parties date (ex: recording with other people) The consent of the other parties is required.
      • Automated individual decision-making, 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 similarly significantly affects you unless such decision (a) is necessary for entering into, or the performance of, a contract between you and us; (b) results from a legally authorized processing; (c) is based on your explicit consent for the processing of your personal data.

      You can make a request or exercise these rights by contacting KPMG Luxembourg at privacy@kpmg.lu.

      If you have more questions about how we process your personal data, please contact our Data Protection Officer at dpo@kpmg.lu.

      In any event, you always have the right to lodge a complaint with the supervisory authority in charge of the protection of personal data in Luxembourg, the Commission Nationale pour la Protection des Données (CNPD) (www.cnpd.lu), or any other competent supervisory authority.

       

      Any change in the processing of your personal data will be reflected in this Fair Processing Notice and you will be informed based on the contact information we have about you.