CCTV monitoring by the Service Voirie's Centre d'Intervention et d'Entretien Cessange (CIEC), and protection of your personal data

The welfare and safety of visitors, and of its own staff, are of the utmost importance for the City of Luxembourg's Service Voirie (Department of Streets). Accordingly, protecting your personal data is a top priority for both the City of Luxembourg and its Service Voirie. This notice asserts our commitment to full transparency, and explains how we process your personal data – i.e. how it is collected, recorded, stored, used, shared, archived, and deleted – as part of our CCTV monitoring operations. It also explains what your rights are in this regard, and how you can exercise them.

As part of its public-interest mandate, the City is responsible for ensuring that roads and thoroughfares in Luxembourg City are kept in serviceable condition. The City's and its Service Voirie's ongoing efforts to improve the city's road systems are beneficial to all users and visitors. The City has introduced CCTV monitoring at its Centre d'Intervention et d'Entretien (Intervention and Maintenance Centre) in Cessange with a view to improving security to the highest possible level. To that end, we may need to process some of your personal data, such as video footage in which you appear.

As such, your personal data may be processed for the following purposes:

• To assist and support the City in fulfilling the task of securing access to buildings outside working hours;
• To ensure the safety of visitors, City staff and suppliers;
• To detect and identify potentially suspicious, dangerous and unlawful behaviour. To prevent acts that threaten the safety of persons – visitors, City staff, watchmen, suppliers, providers, etc. – and property – buildings and their surroundings, vehicles, stocks, etc. – in areas that are particularly exposed. To identify behaviour that could result in serious incidents or accidents;
• To deter ill-intentioned persons from committing criminal offenses;
• To pinpoint the origin of incidents or accidents. To deter ill-intentioned individuals from committing offenses against property, such as theft and vandalism, and to gather evidence in support of established offenses;
• To assist in determining the truth when a theft or loss is reported;
• To respond to data subjects' or public or judicial authorities' requests to access video footage;
• To produce statistics.

In all cases, the City will ensure that such video data is collected for the purposes listed above, and that it is processed in an appropriate manner, and only to the extent that is required to achieve the intended purposes.

Given the location of the Service Voirie site, and the specific risks that were identified in an impact analysis that we conducted, the CCTV monitoring system's operating schedule has been adjusted so that it complies with the purposes listed above, and particularly with the data minimisation principle.

City of Luxembourg's formal commitment

The City hereby formally undertakes to use any data that it collects solely for the above-mentioned purposes. Such data will never be used to assess individuals' performance, or to systematically monitor staff in their workplace. Visitors' data will not be processed for marketing purposes. Personal data will never be sold to third parties.

The City will retain your personal data for as little time as possible, and only for as long as it takes to achieve the purposes for which it is being processed, i.e.:

Images in which you appear (video files) are normally kept for no more than seven days.

Such images may be retained for longer periods of time, should any of the following arise:

• incidents or accidents, for the purpose of sharing data with the police or competent judicial authorities (until a final legal ruling is issued);
• circumstances requiring the City to take steps to defend its interests in a dispute (until the dispute is finally settled). Some of your personal data may be transferred to the City's Service des archives (Archives Department) – for archiving in the public interest, or for historical or statistical purposes – or to the Luxembourg National Archives.

In addition to being accessible to City of Luxembourg departments, your personal data may be transferred to Luxembourg's judicial authorities or the police. This may occur, for example, when a complaint for damage or assault has been filed, and for the purposes of ascertaining a committed offence.
At this time, the City does not transfer your personal data outside the European Union for processing. However, the City may subcontract all or part of the data processing, and transfer your personal data outside the European Union. Should the City do so, we will contractually require contractors to provide guarantees that they are able to safeguard the security and confidentiality of your personal data by implementing appropriate technical and organisational measures, and we will ensure that these guarantees are enforced. The City has taken note that the European Commission has introduced a new mechanism for transferring data to the United States (Data Privacy Framework). Should data be transferred to the United States, we will implement appropriate security and confidentiality measures, as mentioned above, to ensure that the level of protection of your personal data meets the GDPR's requirements.

Further information on how you can exercise your rights can be found in the legal notice published on our website.