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Current version 2025-05-28
1. The Lithuanian and German UAB “TUV NORD Lietuva” Video Surveillance, Photography, Camera Use and Video Data Processing Rules (hereinafter referred to as the Rules) regulate and cover the monitoring, photography, recording of video data, record management (review, storage, transfer, sharing, use) of the premises, buildings and outdoor areas of the technical inspection stations of UAB “TUV NORD Lietuva” (hereinafter referred to as the company), the use of personal video recorders, the granting of access rights and authorizations to process personal data, the procedure for deleting and changing data security breaches and responding to these breaches, as well as the rules for implementing the rights of data subjects and examining requests, ensuring compliance with and implementation of the requirements of the Law of the Republic of Lithuania on the Legal Protection of Personal Data, Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter referred to as the GDPR) and other laws and legal acts regulating the processing and protection of personal data.
2. These Rules have been prepared in accordance with the Law of the Republic of Lithuania on Personal Data Protection (hereinafter referred to as the Law on Personal Data Protection), the GDPR and its implementing legal acts, Order No. 1T-71(1.12) of the Director of the State Data Protection Inspectorate of 12 November 2008 “On the Approval of General Requirements for Organizational and Technical Measures for Personal Data Security”, other laws and legal acts regulating the processing and protection of personal data.
3. The provisions of these Rules apply to the company's employees and clients.
4. The following terms are used in these Rules:
4.1. Data controller – UAB “TUV NORD Lietuva”, company code 110584095, Lentvario g. 7A, Vilnius, e-mail info@tuv-nord.lt , tel. +3706 33 93 000.
4.2. Data controller – UAB “TUV NORD Lietuva” company code 110584095, Lentvario g. 7A, Vilnius, e-mail info@tuv-nord.lt , tel. +3706 33 93 000.
4.3. Data processor of the technical inspection information system – UAB “TUV NORD Lietuva” and the Lithuanian Technical Inspection Companies Association “Transeksta”, Senasis Ukmergės kel. 16, Užubalių k., Vilnius district, e-mail transeksta@vta.lt , tel. +3705 268 52 80.
4.4. Data subject – a natural person whose personal data is processed for the purposes set out in the Rules.
4.5. Personal data – any information relating to a Data Subject whose identity is known or can be directly or indirectly determined.
4.6. Access to video and photographic equipment – physical access or access via electronic means, which gives a person the opportunity to change, remove or update the technical components or software of video equipment, to set the operating parameters of video equipment, and to access personal data collected during video surveillance.
4.7. Video surveillance – the processing of video data relating to a natural person using automatic video surveillance equipment (video cameras), regardless of whether these data are stored on a medium.
4.8. Video surveillance system – servers and/or video data recording devices, video surveillance cameras and data carriers in which video data is stored.
4.9. Video data recording and photography devices – digital devices in the company's asset records intended for capturing, recording, storing, viewing and copying video data.
4.10. Personal video recorder – a mobile device capable of recording video and audio (hereinafter referred to as a video recorder).
4.11. Video recorder user – an employee who records with a video recorder.
4.12. Other terms used in the Rules shall be understood as defined in the ADTAĮ, GDPR and other legal acts of the Republic of Lithuania.
5. The purpose of video surveillance cameras is a preventive security measure to ensure the protection of the property and property rights of the company, employees and customers, public order, a safe environment, to ensure the quality of the services provided by the company, as well as control of the quality of work within the company and in the prevention of corruption. Video surveillance is also carried out for the purposes of controlling vehicles delivered to the technical inspection center, to provide victims with video recordings related to events in accordance with the established procedure, which would help to carry out correct clarifications of controversial situations or case trials.
6. Video surveillance is carried out by cameras at all technical inspection stations of the company. (Appendix No. 1 to the Rules)
7. Video surveillance cameras record:
7.1. Territories of all technical inspection stations: entry and exit zones, vehicle parking lots installed on the company's territory, and all other public spaces on the company's territory;
7.2. Premises of all technical inspection stations: document issuing premises (video surveillance may be carried out together with audio recording) , vehicle inspection lines and all other spaces of the premises of a public enterprise (corridors, entrance, exit areas (video surveillance may be carried out together with audio recording) ).
7.3. Video surveillance of the buildings, internal premises and outdoor areas of the technical inspection stations is carried out by cameras around the clock. During the working hours of the technical inspection station, video data recording is carried out continuously, after working hours - video recording is carried out only after detecting the movement of an object in the premises or area.
8. Video surveillance camera data is recorded on a network attached storage (NAS) device intended for data storage and stored on digital media for at least 30 calendar days. Due to the limited capacity of the hard disk, the video recording device automatically deletes the oldest video recordings and records the latest video stream in the freed space. The personnel responsible for the maintenance of the video surveillance system specified in these Rules ensure the continuity of video data recording and monitor the system for any failures.
9. In order to implement the company's corruption prevention policy and to ensure an objective resolution of disputes regarding the quality of services provided by the company, photography is carried out at the company using video cameras and photographic equipment.
10. Video camera photography is carried out at all technical inspection stations of the company. (Appendix No. 1 to the Rules.)
11. Photographs are taken by video surveillance cameras during the working hours of the technical inspection station, continuously, every 1 minute. Photographs are recorded on a NAS device for data storage and stored on digital media for 3 years.
12. Photography with a photographic device is carried out during the mandatory technical inspection and/or technical expertise of the vehicle. During the mandatory technical inspection, photography with a device is possible for the purpose of performing work quality control within the company, preventing corruption, or in order to record situations that give rise to a dispute between the vehicle owner and an employee of the technical inspection station.
13. When taking photos with a photography device, the photos are directly uploaded from the device to the Technical Inspection Information System data servers (NAS) and stored for 10 years.
14. To ensure the smooth operation of the technical inspection station and the performance of the employees' work functions, at each technical inspection station, on computers used in the service premises, technical inspection employees or their groups specified in the scheme of employees with access to video surveillance/photographs have the opportunity to monitor a live view of the territory and/or premises of their technical inspection station.
15. The list of all technical inspection station cameras with the specified employees or their groups with access rights is specified in the Scheme of Employees with Access Rights to Video Surveillance/Photographs.
16. In order to implement the company's corruption prevention policy and ensure work quality control within the company, the company's manager and the head of the Vilnius Technical Inspection Center have access to live video data from all technical inspection station cameras.
17. All employees of the company specified in these rules who have the right to access live video data undertake to comply with the requirements set out in the legal acts regulating the protection of personal data.
18. All employees of the Vilnius Technical Inspection Center have the right to use video recorders at all technical inspection stations of the company specified in Annex No. 1 to the Rules.
19. Video recorders are issued to users by a responsible employee - the head of the technical inspection station, shift supervisor or other employee designated as responsible for the video recorder.
20. The video recorder is issued to the responsible employees of the technical inspection station through the work equipment accounting module in the company's document management system. The company's IT specialist is responsible for issuing video recorders and assigning the recorder to the employee in the document management system.
21. Video recorders are used for:
21.1. in situations where there is a threat to the safety of the company's employees and/or customers, a danger to life or health, or to the property of the company's employees and/or customers;
21.2. a client or another person committing an obvious violation of the law or potentially similar illegal activity on the company's territory;
21.3. in conflict situations when communicating with the company's clients or other persons, when they avoid carrying out lawful instructions or requirements of the company's employees;
21.4. prevent possible cases of corruption;
21.5. upon the instruction of the manager, in order to verify the quality of the work performed by the employee, conduct monitoring of the quality of the employee's work;
21.6. Upon the instruction of the head of the Vilnius Technical Inspection Center and/or the head of the technical inspection station, during the performance of the quality control inspection of the mandatory technical inspection of vehicles carried out by the Lithuanian Transport Safety Administration.
22. When using a video recorder, it is prohibited to:
22.1. temporarily or permanently transfer the video recorder or its data to third parties (including law enforcement agencies, etc.);
22.2. independently delete or copy data from the internal memory of the video recorder;
22.3. use video recorders in rooms where a person expects complete privacy, i.e. in toilets, showers, etc.
23. The user of a video recorder, having turned on the video recorder, shall immediately orally inform the person that a video recorder is being used, recording image and sound, except in cases where this is impossible due to objective circumstances.
24. A user of a video recorder, having recorded a possible violation of the law committed by a person with a video recorder, shall immediately inform his or her direct supervisor thereof.
25. Every working day (at the end of the shift), the video recorder user returns the video recorder to the responsible employee of the technical inspection station. The information recorded by the video recorder is automatically and/or manually transferred to a specially created publicly inaccessible storage location on the server. At the end of the working day (at the end of the shift), the responsible employee must check (if the video recorder was used) whether the data from the video recorder has been transferred and, if the data has not been transferred, report the failure to the company's IT specialist.
26. Video recorders record the environment, check the condition of vehicle parts, their damage, non-compliance with requirements and other circumstances that are relevant to the results of the inspection and the inspector's conclusion.
27. Video recorder data is stored in storage devices for 30 (thirty) calendar days. After this period, the data is deleted automatically or manually from the video data storage equipment servers. The company's IT specialist is responsible for controlling data deletion.
28. If the video recorder data from the video data storage devices must be stored for a period longer than 30 calendar days, the person interested in the storage shall inform the IT specialist in writing, indicating what video recorder data is requested to be stored (indicating the date, time, technical inspection station), for what period and for what reasons. In such a case, the IT specialist shall fill in the Video Surveillance and/or Photography Data Transmission and Recording Log (Appendix No. 3 to the Rules), indicating the desired storage period. The video data shall be destroyed as soon as the reasons for which their destruction was postponed cease to exist.
29. If video data from video data storage devices is required for an investigation, it may be deleted only upon the instruction of the person who, having the right to do so, requested its storage, or upon the expiry of a specified period.
30. When conducting an inspection at the Company regarding circumstances related to the performance of the Company's employee's job duties, upon receipt of a complaint from a client or another person regarding the actions of the company's employees, the video recorder recording is stored until the end of the investigation.
31. The following persons have the right to view the video data recorded by the video recorder:
31.1. The head of the Company, the head of the Vilnius Technical Inspection Center, the head of the IAS and/or an employee authorized by these persons, as well as employees responsible for the maintenance of the video surveillance system and other employees for whom viewing video data is necessary to perform their job duties;
31.2. Person/employee whose image data is being processed;
31.3. Law enforcement and other institutions in accordance with the procedure established by legal acts.
32. All recorded data from the video recorder, video surveillance cameras and photography shall be processed by the head of the company's information systems maintenance department and an information technology specialist (hereinafter referred to as the employees responsible for the maintenance of the video surveillance system), who shall be responsible for the organisation of video surveillance, the processing of video data, their transfer to third parties and the protection of video surveillance, recording and photography data under the conditions specified in these rules, except in cases where there are technical failures in the system or preventive work is being carried out. These employees, who have the right to access the video data, have signed a pledge to keep personal data confidential and undertake to comply with the requirements set out in the legal acts regulating the protection of personal data.
33. Employees responsible for the maintenance of the video surveillance system must:
33.1. ensure that video surveillance, photographs and/or data recorded by a video recorder are not used for purposes other than those defined in these Rules;
33.2. ensure that data is accessible only from the internal computer network;
33.3. ensure that video surveillance cameras are installed and/or photographs are taken in such a way that, taking into account the established purpose of video surveillance and/or photography specified in these Rules, video surveillance is carried out and/or photographs are taken in no larger part of the territory or premises than is necessary and no more video data is collected than is necessary.
33.4. comply with the basic principles of video data processing and confidentiality and security requirements established in the Act on the Protection of Personal Data, the GDPR, these Rules and other legal acts;
33.5. ensure that the video surveillance system and the equipment used for video surveillance and recording are in good technical condition, and that technical malfunctions of this system and equipment are eliminated promptly, using all available technical resources;
33.6. take organizational and technical personal data security measures to prevent accidental or unlawful destruction, loss, alteration, disclosure of video data, as well as any other unlawful processing;
33.7. to store video data in video data recording devices and/or media;
33.8. not to disclose, transfer or create conditions for access to video data by any means to persons who do not have the right to do so;
33.9. ensure that information boards (video surveillance signs) are posted at the entrances to the company's building, premises, and territories where video surveillance is carried out with the following information: "For the purpose of protecting persons and property, the territory and premises are monitored by video cameras", which also provide contact information: UAB "TUV NORD Lietuva", company code 110584095, Lentvario g. 7A, Vilnius, tel. +3706 33 93000, e-mail dap@tuv-nord.lt ;
33.10. ensure that information boards are posted and visible before entering the video surveillance area;
33.11. Record the transmission of video surveillance and/or photography data in the Video Surveillance and/or Photography Data Transmission Log.
33.12. ensure that the area captured by video surveillance cameras does not include a residential premises and/or a private territory belonging to it or an entrance to it, as well as premises where the data subject reasonably expects absolute protection of privacy and where such surveillance would degrade human dignity.
34. Employees responsible for the maintenance of the video surveillance system, or other employees of the company, who notice that the video surveillance and/or photographic data being processed has become accessible (attempts are being made to access it) to persons who do not have the right to process the specified data, must:
34.1. immediately take all possible measures to terminate unlawful access to the processed personal data;
34.2. immediately inform the employee responsible for maintaining the video surveillance system;
34.3. immediately inform the employee responsible for personal data protection about the incident, who must register the incident in accordance with the procedure established by the company.
35. Access rights to recorded video surveillance and photography data shall be terminated upon the termination of the authority or employment relationship of the employee processing the video data, or upon a change in the employee's functions, for which access to video data is not required.
36. In cases and in accordance with the procedure established by legal acts, the company provides its processed video surveillance and/or photography data to law enforcement institutions and other persons to whom such data is required to be provided by laws or other legal acts or to whom the company, in accordance with the procedure established by legal acts or contractual obligations, provides such data in the performance of its functions (Association of Technical Inspection Companies “Transeksta”, Lithuanian Transport Safety Administration, State Enterprise “Regitra”, insurance companies), as well as at the requests of data recipients if at least one of the conditions for processing personal data of a lawful person specified in Article 6 of Regulation (EU) 2016/679 is met. The request must indicate the purpose of using the video data, the legal basis for providing and receiving it, and the scope of the video data requested.
37. The decision on the provision of video data is made by the company manager or a responsible person authorized by him.
38. All employees have the right to access their image data, and when exercising this right, they must comply with the requirements set out in the legal acts regulating the protection of personal data.
39. To ensure the security of video data, the following organizational and technical personal data security measures are implemented:
39.1. access to live video surveillance is granted only to those employees who need live video surveillance data to perform their job functions;
39.2. Only the employees responsible for the maintenance of the video surveillance system specified in these Rules have the right to process recorded video surveillance and photographic data;
39.3. protection, management and control of access to video data is ensured (by passwords);
39.4. protection of personal data against unauthorized access to the local network by electronic means of communication is ensured;
39.5. the security of the premises where video data is stored and the appropriate protection of data storage devices are ensured (data storage devices are stored in locked rooms/cabinets, access to the relevant premises by unauthorized persons is restricted, etc.);
39.6. computer equipment is protected against malicious software (installation, updating of antivirus programs, etc.).
39.7. information about the fact that video surveillance is being carried out is provided in all cases, regardless of the fact that video surveillance is not being carried out in some designated areas at that time (for example, the video surveillance camera is not operating all the time, operates at a set frequency, etc.).
40. The data subject has the following rights: to receive information about data processing; to access the data; to request deletion of data ("right to be forgotten") if the video/photograph data is stored longer than the retention period set out in these Rules; to restrict data processing; to object to data processing.
41. An image captured by video surveillance cameras or a photographic device (if saved) or a copy thereof may be released only upon written request of the data subject or in accordance with the procedure established by legal acts.
42. The request of a data subject wishing to receive a photograph or video recording (copy) that captures not only him or her but also third parties must indicate the purpose of using the personal data, the legal basis for providing and receiving it, and the scope of the personal data requested.
43. In order to ensure the rights of third parties, the company reserves the right not to provide video data that captures not only the data subject, but also third parties.
44. The company, having received an inquiry from a person regarding the processing of video data related to him, shall respond no later than within 30 calendar days from the date of receipt of the person's request whether the video data related to him is processed and stored, and if stored, about the procedure for providing this data.
45. In accordance with the data subject's request for access to his or her video data, the requested video data may be provided to the data subject by enabling the viewing of the video recording on the company's premises and/or by providing a copy of the video on an external data carrier or a photograph, if the video data is stored.
46. At the request of law enforcement authorities or other institutions to which the company undertakes to provide data in accordance with the procedure established by legal acts, an image (copy) recorded by video surveillance cameras or a photographic device may be released without the consent of the persons captured in the image.
47. In order to protect the personal data and interests of the company's customers, third parties are allowed to photograph, film or make audio recordings in all technical inspection station premises and territory only upon request and prior permission from the company's administration, indicating the reason for which the filming/photographing/making of audio recordings is desired and whether there is a legal basis for such actions.
48. The decision on permission to take photographs, film or make audio recordings in the premises and territory of technical inspection stations is made by the head of the company or a responsible person authorized by him.
49. These Rules are published on the company's website www.tuv-nord.lt and on information stands at all technical inspection stations.
50. All employees of the company are familiarized with the Rules upon signature and thus undertake to comply with them and other legal acts establishing requirements for the processing of personal data.
51. Employees of the Company who violate the requirements of these Rules shall be held liable in accordance with the procedure established by legal acts.
UAB "TUV NORD Lithuania"
Video surveillance, photography, cameras
usage and image data processing
Annex No. 1 to the Rules
| IAS No. | IAS name | Address |
|---|---|---|
| 001 | Vilnius IAS | Lentvario St. 7A, Vilnius |
| 003 | Oatmeal IAS | Old Ukmergės Road 16, Užubaliai village, Avižieniai parish, Vilnius district |
| 010 | Viršuliškės IAS | Viršuliškių street 36, Vilnius |
| 013 | Ukmerge IAS | Deltuvos St. 33A, Ukmergė |
| 015 | Šalčininkai IAS | Vilnius St. 5D, Šalčininkai |
| 017 | Sirvintos IAS | Kalnalaukio St. 10, Širvintos |
| 019 | Aukštadvaris IAS | Technikumo St., Aukštadvaris, Trakai District. |
| 024 | Elektrėnai IAS | Sabališkių St. 1T, Elektrėnai |
| 026 | New Vilnius TAS | Linksmoji St. 5A (New Vilnius), Vilnius |
| 029 | Nemenčina IAS | Parčevskių g. 2, Vilkaraisčio village, Nemenčinės sen., Vilnius district. municipality |
TUV NORD Lithuania is a member of the international TÜV Nord group of companies
