CCTV Privacy Notice

St George’s International School Luxembourg ASBL (hereafter referred to as “we”, “us” or the School) is committed to protecting your privacy and personal data. This privacy notice (hereafter the "notice") aims to inform about how we collect, use, disclose, store and process personal data of our on premises - visitors in the context of managing the CCTV (together “you”).

 

WHY DO WE PROCESS YOUR PERSONAL DATA?

The School operates a CCTV (video surveillance) system in its campus to ensure the security of persons, premises and assets.

The CCTV system is used exclusively for the following purposes:

  • To secure access to school buildings and facilities;
  • To ensure the security of students, staff, visitors and service providers;
  • To prevent, reduce, detect and investigate incidents like theft, vandalism and other security incidents
  • To secure access to restricted areas, including server rooms and technical facilities;

The CCTV system is not used for monitoring of employees' work performance, productivity, attendance, working hours or behaviour.

 

WHAT IS THE LEGAL BASIS FOR PROCESSING?

The School processes personal data obtained through its CCTV system on the basis of its legitimate interests, in accordance with Article 6(1)(f) of the General Data Protection Regulation (GDPR).

The CCTV system is necessary to support the School's legitimate interests in:

  • maintaining a safe and secure environment for students, staff, parents, visitors and other individuals present on School premises;
  • protecting School buildings, facilities, equipment and other assets from theft, damage, vandalism, unauthorised access or other security incidents;
  • preventing, detecting and investigating security incidents, accidents and unlawful activities affecting the School or individuals on its premises; and
  • safeguarding critical areas.

The CCTV system is designed and operated in a proportionate manner and only monitors areas where video surveillance is necessary to achieve the above purposes.

 

AREAS UNDER CCTV SURVEILLANCE

CCTV cameras are installed only in areas considered necessary and proportionate for security purposes like building entrances and exits; reception area; parking areas; access gates; emergency exits and other critical areas.

The School seeks to limit camera fields of vision to areas strictly necessary for achieving the stated purposes and avoids filming neighbouring properties or public areas unless unavoidable and proportionate.

 

WHO HAS ACCESS TO CCTV FOOTAGE

Access to CCTV footage is strictly restricted to authorised persons who require such access for their duties.

 
Internal Recipients
  • Certain members of the technical and security teams;  (live footage and recordings)
  • School Management, if necessary for investigations or incident handling (recordings)
External Recipients
  • The School may share footage where necessary with:
  • If necessary: CCTV service providers and technical support providers acting as processors, for maintenance or troubleshooting purposes only (live footage and recordings).
  • On request: competent public authorities (law enforcement authorities; judicial authorities; emergency services.) (live footage or /and recordings)

Any disclosure will be limited to what is necessary and proportionate for the specific purpose.

 

WHO LONG DO WE KEEP THE DATA?

CCTV recordings are retained for a maximum of 14 days from the date of recording.

Recordings are automatically deleted after this period unless preservation is required for for the investigation of a security incident; for the establishment, exercise or defence of legal claims; to comply with a request from a competent public authority.

In such cases, relevant footage may be retained for the duration necessary to address the incident or comply with legal requirements.

 

WHAT ARE YOUR RIGHTS?

In accordance with the applicable data protection law (and subject to conditions and restrictions set forth therein), you may exercise at any time the following rights in relation to your personal data:

  • right of access: which enables you to obtain from us confirmation of whether your personal data is being processed or not and, if so, obtain access to such data;
  • right to rectification: which enables you to obtain from us the correction of any of your personal data;
  • right to erasure: which enables you, in certain specific cases to obtain from us the erasure of your personal data;
  • right to restriction of processing: which enables you, in certain specific cases to restrict the processing of your personal data by us;
  • right to object: which enables you to object to the processing of your personal data when certain conditions are met;
  • right to data portability: which enables you, in certain cases (subject in particular to technical feasibility and only with regard to the data you have provided) to request receipt of your personal data in a structured and commonly machine-readable format;
  • right to lodge a complaint: under which you are entitled to lodge a complaint with the the CNPD;
Commission Nationale pour la Protection des Données (CNPD)

15 Boulevard du Jazz
L-4370 Belvaux
Luxembourg
www.cnpd.lu
  • right to withdraw your consent at any time: you can withdraw your consent at any time when the processing activity is based on your consent.

To exercise any of these rights, you may contact us:

  • by email: DPO@st-georges.lu
  • by postal post : We reserve the right to update this privacy notice at any time, and we will provide you with a new one when we make substantial changes. 
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