Video Surveillance Policy

Approval date: 01.09.2026

1. Purpose

The purpose of this Video Surveillance Policy is to establish the procedure for organising video surveillance, processing Personal Data, and storing, using and deleting video surveillance recordings at the Uniflow By Rixwell accommodation facilities managed by SIA “Univer” (hereinafter – the Controller).

  • the safety of guests, users, employees and visitors;
  • protection of the company’s property;
  • prevention and investigation of violations;
  • obtaining evidence in the event of incidents;
  • compliance with European Union and Latvian laws and regulations.

2. Scope

  • all employees of SIA “Univer”;
  • guests and long-term users;
  • visitors;
  • cooperation partners;
  • service providers.

3. Legal Framework

Video surveillance is carried out in accordance with:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR);
  • Personal Data Processing Law;
  • Labour Law (in relation to employees);
  • other applicable Latvian laws and regulations.

4. Data Controller

SIA “Univer”

Registration No.: 40203430709

Registered address: Elizabetes iela 31-8, Riga, Latvia

Email: [email protected]

Telephone: 27739888

5. Purposes of Video Surveillance

Video surveillance is carried out only for the following purposes:

  • protection of human life and health;
  • protection of property;
  • prevention of theft, vandalism and other violations;
  • documentation of incidents;
  • support of civil claims or legal proceedings;
  • protection of the Controller’s legitimate interests.

Video surveillance is not used for continuous monitoring of employees or guests.

6. Legal Basis

Video surveillance is carried out on the basis of Article 6(1)(f) GDPR – the Controller’s legitimate interests.

7. Camera Locations

Video surveillance cameras may be located:

  • at the main entrances;
  • at reception;
  • in corridors;
  • in lift lobbies;
  • in car parks;
  • in the external territory of the building.

8. Areas Where Video Surveillance Is Prohibited

Video surveillance is not carried out:

  • in guest rooms;
  • in sanitary facilities;
  • in showers;
  • in changing rooms;
  • in other premises where a person may reasonably expect complete privacy.

9. Scope of Recorded Data

The video surveillance system may record:

  • a person’s image;
  • date;
  • time;
  • location of the event.

Audio recordings are not made unless specifically justified and compliant with applicable laws and regulations.

10. Operating Hours of Video Surveillance

Video surveillance is carried out continuously – 24 hours a day, 7 days a week.

11. Retention Period for Recordings

Video surveillance recordings are stored for up to 30 days.

If a recording is required for:

  • the police;
  • a court;
  • an insurer;
  • an incident investigation;

it is retained until the relevant process has been completed.

After the retention period expires, recordings are automatically deleted or overwritten.

12. Access to Recordings

Access to video surveillance recordings is limited to:

  • the company’s Management Board;
  • an authorised security specialist;
  • an authorised IT administrator (for technical maintenance purposes);
  • state authorities in cases provided for by law.

Each instance of access is documented.

13. Disclosure of Recordings

Video surveillance recordings are disclosed only to:

  • the State Police;
  • the Prosecutor’s Office;
  • a court;
  • other competent authorities;
  • the data subject, provided this does not restrict the rights of other persons.

Before recordings are disclosed, the protection of other persons’ data is assessed. Where necessary, image masking or other anonymisation techniques are used.

14. Security Measures

The video surveillance system is protected by:

  • individual user accounts;
  • passwords;
  • access-right restrictions;
  • firewalls;
  • encryption (where applicable);
  • backups where necessary to ensure system operation.

15. Rights of Data Subjects

Every person has the right to:

  • receive information about video surveillance;
  • request access to their Personal Data;
  • request deletion of data where there is a legal basis;
  • request restriction of processing;
  • object to processing;
  • lodge a complaint with the Data State Inspectorate.

16. Employee Obligations

Employees are required to:

  • not disclose video surveillance recordings to unauthorised persons;
  • use recordings only for the performance of their work duties;
  • not copy recordings without authorisation;
  • immediately report security incidents.

17. Data Protection Incidents

If any of the following is identified:

  • unauthorised access;
  • a data leak;
  • loss of recordings;
  • unauthorised copying;

the company’s management must be informed immediately.

If an incident creates a risk to the rights and freedoms of natural persons, the Controller acts in accordance with GDPR requirements, including, where necessary, notifying the Data State Inspectorate and informing the affected persons.

18. Video Surveillance Notices

At all entrances to the territory and premises where video surveillance is carried out, a clearly visible information notice is displayed stating:

  • that video surveillance is carried out in the territory;
  • the name of the data controller;
  • contact information;
  • a reference to the full Privacy Policy.

19. Policy Review

This Policy is reviewed:

  • at least once every two years;
  • after significant changes to the video surveillance system;
  • after changes to laws and regulations;
  • after significant data protection incidents.

20. Final Provisions

This Policy is binding on all employees of SIA “Univer” and persons who have been granted access to the video surveillance system.

The Management Board of SIA “Univer” or a person authorised by it is responsible for the implementation and supervision of this Policy.