Komatsu Forest CCTV Notice
This Camera Surveillance Notice (hereinafter “Notice”) has been drafted by Komatsu Forest AB (hereinafter “Komatsu Forest” or “we”) in its endeavour to comply with the General Data Protection Regulation (GDPR) and the Swedish Camera Surveillance Act. This notice complements the first layer of information available on warning signs posted at key points around the monitored areas. Both this notice and the warning signs serve to inform our employees or contractors and any third parties (hereinafter “you”) being monitored by our CCTV systems.
1. Identity of the Data Controller
- Controller Name: Komatsu Forest AB
- Registered Address: Handelsvägen 22, 901 37 Umeå, Sweden
- Data Protection Officer: GDPR@komatsuforest.com
2. Purpose of Surveillance
The personal data processed under this notice concerns camera footage in the form of visual images in colour only. We do not record sound. The camera footage is recorded for the following purposes:
- Prevention, deterrence, and detection of criminal activity.
- Monitoring activities performed by third parties on Komatsu Forest grounds.
- Prevention, detection and avoidance of accidents and to limit the effects of accidents.
- Monitoring of deliveries to verify whether an intervention by a worker is required.
Camera footage will not be processed for any other purposes than those stated in this policy,
unless prior notice is provided.
3. Legal Basis
In general, the legal basis for this surveillance, for all of the above processing purposes, is Article
6(1)(f) of the GDPR, which allows processing based on the legitimate interests of Komatsu Forest
in maintaining safety, security, and for the detection of fraud.
Where we monitor for the purpose of verifying whether an intervention by a worker is required, our
processing is based on the legitimate interest of Komatsu Forest in maintaining operational
control over its activities.
4. Scope of Surveillance
Komatsu Forest employs a range of both outdoor and indoor cameras to monitor its premises.
These areas are marked in Annexes I and II accessible at the end of the Notice. These
surveillance areas have been carefully reviewed to ensure that the monitoring is necessary and
justified for security, safety, and operational purposes. Monitoring is strictly limited to areas
where it is essential, and the footage captured is handled with access limits and diligence.
5. Recording, Storage and Retention of Data
The cameras are recording continuously to ensure adequate monitoring and security. Camera
footage is stored locally when movement is detected by the cameras. The retention period varies
depending on the remoteness of the surveilled location. Where there is a continuous passage of
Komatsu Forest personnel, the retention period is set to six (6) days. In all other cases, we have
chosen to implement a maximum retention period of thirty (30) days.
After the expiry of the retention period, the footage is automatically deleted, unless a longer
retention period is required for security purposes or for the fulfilment of legal obligations. While
the footage is not stored on the cloud, it may be accessed via the SaaS platform directly from the
camera.
6. Recipients of the Data
The cameras and associated applications are provided by a third-party service provider. However,
any footage is managed internally by designated Komatsu Forest employees. Access to the
footage is limited to specifically authorized personnel on a need-to-know basis. Sharing of
footage with third parties, including law enforcement authorities, is strictly controlled and can
only occur with prior approval, when legally required or necessary.
7. Your Rights as a Data Subject
As an employee, contractor, visitor or other third party monitored by Komatsu Forest's camera systems, you are entitled to exercise your rights under the GDPR. These rights include:
- Right to Access: You may request access to footage that contains your personal data.
- Right to Erasure: You may request the deletion of footage, subject to legal and operational limitations.
- Right to Object: You have the right to object to the processing of your personal data if you believe it is unjustified.
- Right to Restrict Processing: Under certain circumstances, you may request that we restrict the processing of your data.
- Right to Lodge a Complaint: You may lodge a complaint with the Swedish Data Protection Authority (IMY) if you believe your rights have been violated.
8. Automated Decision-Making
The camera surveillance system used at Komatsu Forest does not involve automated decisionmaking processes. All footage is reviewed manually by authorized personnel when necessary.
9. Further Information and Transparency
For more information about privacy and data protection at Komatsu Forest, you may:
• Access the Privacy Notice on our website.
• Visit our reception desk for information and a physical copy of this notice.
• Scan the QR code available on the warning signs posted in monitored areas for immediate
access to this information.
• Furthermore, Komatsu Forest employees or contractors may also refer to our Internal
Privacy Policy and Internal CCTV Policy stored in our internal systems.
If you have any questions or concerns regarding this notice or camera surveillance at Komatsu
Forest, feel free to contact us at GDPR@komatsuforest.com.