European Data Protection Day

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​Today, 28 January, is the European Data Protection Day. The main goal of this celebration is raising awareness of European citizens of their rights and obligations in the field of personal data protection and privacy as a fundamental human right. On this occasion, please, allow us to bring to your attention the following two topics that are always relevant in business environment: video surveillance of business premises and supervision of employee electronic communications. Namely, if you use video surveillance as a security measure for protecting your business premises, you should know that a video surveillance recording constitutes personal data of a person captured in the recording, e.g. your employee or a visitor. Therefore, the issues concerning the collection, processing, keeping, protection and deletion of such recordings must be regulated in compliance with the provisions of the Personal Data Protection Act and applicable regulations. For example, a video surveillance notice must to be displayed visibly and clearly. Further, employee privacy protection is additionally regulated by the Labour Act. In principle, all issues concerning the processing and protection of employee personal data must be regulated by Labour Bylaws. Inter alia, in the present era of modern communication technologies, it is important to regulate the use of corporate computer systems and networks by employees, including the supervision of work-related employee electronic communications. The implementation of such supervision must be based on a lawful and justified purpose and an applicable internal resolution or another instrument made known to employees. Otherwise, the supervision of any employee electronic communications, even work-related, shall constitute a violation of employees' privacy. For example, in order to protect your business operations, as a type of supervision, it is possible to use an automated tool that monitors e-mail based on certain key words (e.g. business secret, terrorism, director and the like) and highlights any messages containing those words. We hope you will find the above information interesting and useful. Should the need for any further information or clarifications on the topic of personal data protection within your business environment arise, please, do not hesitate to contact us.