Notice to data subjects pursuant to Article 76(3) of the Personal Data Protection Act (Official Gazette of the Republic of Slovenia no. 163/2022, ZVOP-2) as regards the carrying out of video surveillance in the area, premises, and facilities of the company BAVARSKI STOLP d.o.o. (Hotel InterContinental Ljubljana).

1. Controller carrying out surveillance

• BAVARSKI STOLP, investicijsko podjetje, d.o.o.
• Slovenska cesta 59, 1000 Ljubljana
• Company registration number: 6779689000, tax number: SI 71946349
• E-mail: ljuha.info@ihg.com
• Responsible person at the controller: Duško Božić, CEO

1. Data Protection Officer’s (DPO) contact information

Petra Jereb, e-mail: info@opj.si

1. Purpose of surveillance

Video surveillance is carried out in order to ensure the safety of people and property in the area, facilities, and premises of the company BAVARSKI STOLP d.o.o. (Hotel InterContinental Ljubljana) and in order to monitor entries and exits, all in accordance with the provision of Articles 77(1) and 78(1) of the Personal Data Protection Act (ZVOP-2) and the provision of Article 6(1), point (f) of the General Data Protection Regulation – GDPR.

It is strictly necessary for the safety of the employees, guests, and their property, as well as the company’s property that video surveillance is carried out at entry points to the hotel and in all places where guests and employees have freedom of movement. Due to the large area of the hotel, any other manner of protection for people and property would be less efficient.

For that purpose, we process the following personal information: data subject’s recording (image), location information, and date and time of recording. 

Prior to implementing the video surveillance, the controller performed a balancing test with which they ascertained that their legitimate interest prevails over the data subjects’ legitimate expectations of privacy in the footage. In summary, the controller ascertained that a large number of guests and external visitors flow in and out of the hotel on a daily basis, while the surface area of the hotel is so large that the company can ensure the safety of its property and people in the hotel solely through the use of a video surveillance system. The guests expect a high level of safety, particularly those who stay overnight in the hotel. The guests’ collective interests for a safe stay in the hotel prevail over the possible interests of data subjects to privacy. In this context, it is important that only common areas are under video surveillance, where multiple hotel guests, visitors, or employees have access, however, in hotel rooms, sanitary facilities, changing rooms, elevators, offices etc., a higher level of privacy is ensured and there is no video surveillance on such premises.

1. Users of the video surveillance system footage

These are authorised persons in the BAVARSKI STOLP d.o.o. company and the contractor for security services in accordance with the decision regarding the implementation of video surveillance.

1. Retention period for video surveillance system footage

We will not store your personal information collected on the basis of video surveillance for longer than 30 days. In the case that we need the information for the purpose of criminal or other official proceedings, we will store it for the entire duration of such proceedings. The information shall be forwarded to the competent national authorities (the police, court, and others) pursuant to the relevant decision of the competent authorities and statutory requirements.

Other information related to carrying out the surveillance and further processing:

• there is no further processing or particular impacts of processing in relation to the video footage;
• video footage is not transferred to third countries;
• the controller does not record sound in the scope of video surveillance;
• the events are monitored live, whereby access to live footage is available only to the controller’s authorised persons and the contractor for security services;
• there is no automated decision-making, including profiling;
• sound intervention is not possible.

1. Notice of data subject’s legal remedies regarding the video surveillance system footage:

Data subjects who recognise themselves in the video surveillance system’s footage or a data subject recorded by the video surveillance camera has the right to:

• access the personal information, i.e., the right to inspect the video surveillance system footage that is related to the recorded person;
• rectify (blur – anonymise), delete, or restrict the processing of the video surveillance system footage;
• object to the processing of the video surveillance system footage;
• portability of the video surveillance system’s data (a copy of the footage).

After the data subject has been informed, they submit a request to the e-mail address ljuha.info@ihg.com or to the address BAVARSKI STOLP d.o.o., Slovenska cesta 59, 1000 Ljubljana, Slovenia.

BAVARSKI STOLP d.o.o. shall satisfy a justified request within one month, while in the case of a complex nature of the requests or a larger number of requests, the deadline for fulfilment can be extended for another two months. BAVARSKI STOLP d.o.o. shall inform the data subject of such extension and the reasons for it.

1. Right to submit a complaint regarding the processing of personal information:

The data subject can submit a potential complaint related to the processing of personal information to the e-mail address ljuha.info@ihg.com or by post to the address: BAVARSKI STOLP d.o.o., Slovenska cesta 59, 1000 Ljubljana, Slovenia.

Every data subject also has the right to submit a complaint directly to the Information Commissioner if they believe that the processing of personal information related to them is in breach of the legislation in force. Contact: Republic of Slovenia, Information Commissioner, Dunajska cesta 22, 1000 Ljubljana, Slovenia. Telephone: +386 (0)1 230 97 30, e-mail: gp.ip@ip-rs.si.

Ljubljana, 15 September 2023

BAVARSKI STOLP d.o.o.
Duško Božić
CEO