Electronic monitoring at the vacation properties of AFL - the Union of General and Special Workers in East Iceland
Some parts of the AFL vacation properties are now equipped for electronic monitoring with a security camera system. Where this is the case, it has been labelled on site, in keeping with law.
According to Act No. 90/2018, on Data Protection and the Processing of Personal Data, electronic surveillance must have an objective purpose, and the processing of data thereby obtained is subject to certain rules. The purpose of surveillance in AFL vacation areas is explained below, as well as how data from the security systems is processed.
- Reasons for surveillance
- The main purpose of this surveillance is to protect the security of AFL members and of their guests and property, as well as AFL property.
- That involves checking that no unauthorised parties have access to this building.
- AFL also reserves the right to observe how renters treat common areas, including the rubbish storage room, basement car park and bicycle storage room.
- Arrangements on site
At the AFL vacation property in Stakkholt, cameras are positioned at two outdoor spots on the ground floor, three places in the underground car park, on every stair landing and at two locations per floor in the outdoor passageways. One camera is located in the rubbish storage room and another in the equipment and bicycle storage room. The total is 19 cameras.
- Data storage
All of the cameras are set for continuous recording. All of the footage is kept for 90 days and is then automatically deleted. The stored photographic material is kept on a server owned and supervised by AFL, ensuring that no unauthorised parties obtain access to the material.
- Access to the photographic material
There are only two AFL employees who have access to photographic material from the security cameras. These two AFL employees are not permitted to examine the camera footage without a specified reason; furthermore, they shall log each examination of photographic material that is on the server. If such an examination is directed at a particular individual, s/he shall be notified that the material has been examined and what the reason was for this examination.
- Real-time checks
The AFL employees who are able to access the cameras might sometimes check on movements through union property; these checks would be random and only of brief moments. Such checks would not be directed at any particular individual and do not require notification.
- The rights of those monitored
Those who are being monitored have the right to access the material recorded of them unless the interests of other people matter more. Since the photographic material will not be examined in any organised manner and no records will be kept of those appearing in it, AFL is not of the opinion that any further processing occurs of data on particular individuals. If a special examination does occur, for instance of movements around a particular apartment, then that shall be considered a processing of personally identifiable data regarding those staying there at the time. The renter shall be informed of the examination having occurred, and those who were particularly examined shall thereby be entitled to examine the photographic material that was recorded of them.
- Those who can obtain access to the information
AFL will not hand over the photographic material from the security cameras to any third party unless this is legally permissible. If the police request such material due to a criminal investigation, AFL will provide the police with full access to the requested material. If an individual believes for example that her/his car was damaged in the building's underground car park, this person will not receive access to photographic material from the security camera. Instead, an AFL employee will examine the camera footage and notify the police if this employee feels the photographic material clearly shows that damage was done to the car. A police request for this footage would be complied with.
- Responsible party; right of recourse
AFL's general manager is the party responsible for security cameras and for their installation and operation, as well as for compliance with laws and regulations when material from electronic monitoring is being processed. Should an AFL member feel that s/he has been infringed upon through the system's operation, s/he is requested to contact the union's data protection officer for advice.