Video surveillance privacy notice

VIDEO SURVEILLANCE PRIVACY NOTICE

The Centre National Sportif et Culturel Coque (hereinafter “CNSC” or “we”) attaches particular importance to the protection of your personal data and respect for your privacy when you are present in our facilities. This notice aims to inform you clearly and transparently about the operation of the video surveillance system implemented, as well as the rights you have.
This notice complements the CNSC Data Protection Policy

1 Identity of the Data Controller

The data controller within the meaning of the General Data Protection Regulation (GDPR) is the Centre National Sportif et Culturel Coque.
Address: 2, Rue Léon Hengen, L-1745 Luxembourg
Telephone: +352 43 60 60 1
Email: info@coque.lu

2 Data Protection Officer (DPO)

For any questions regarding video surveillance, you may contact the Data Protection Officer (DPO):
By email: dpo@coque.lu
By mail:
Care of the DPO of the Coque
Address: 2, Rue Léon Hengen, L-1745 Luxembourg

3 Purposes of Processing

The video surveillance system pursues the following objectives:
•    Ensure the safety of persons: protect CNSC users, visitors and staff against aggression, dangerous behaviour or any other incident that may compromise their safety;
•    Ensure the security of property and infrastructure: prevent and detect intrusions, damage, theft or any act that may harm CNSC facilities and equipment;
•    Enhance aquatic safety through video detection of distress situations.
The system is not intended to monitor individual staff members in the performance of their work.
Video detection of distress situations has the sole objective of contributing to aquatic safety. It does not result in an automated decision producing legal effects within the meaning of Article 22 of the GDPR.

3.1  Legal Basis for Processing

The implementation of the video surveillance system is based on the legitimate interest of CNSC in ensuring the safety of persons and infrastructure and preventing incidents (Article 6.1(f) of the GDPR). This legitimate interest has been balanced against the rights and freedoms of data subjects, and CNSC implements appropriate safeguards, in particular: limiting filmed areas to relevant spaces, restricting access to images to authorized personnel only, limiting data retention periods and ensuring traceability of access.

3.2  Categories of Data Subjects and Data Processed

Data subjects include in particular visitors, users of sports facilities, staff members, service providers and external contractors (technicians, subcontractors, delivery personnel), as well as any person passing through areas under video surveillance.
The data collected consists of images to which information relating to their recording is associated, such as the date and time of recording and location.
The system also records technical data necessary for system security, in particular the identifiers of authorized users and access and consultation logs.

3.3  Filmed Areas and On-Site Information

Cameras are installed in and around CNSC premises in areas presenting security concerns (for example: entrances/exits, reception areas, corridors and circulation areas, parking areas and building access, technical or storage areas). Cameras are not intended to film areas where privacy expectations are high (for example: toilets, changing rooms, showers and similar spaces).

3.4 Data Retention Periods

Recorded images are retained for a maximum period of thirty (30) days. In the event of an incident, relevant data may be extracted and retained for the duration necessary to process the incident, investigate or handle any potential proceedings.

3.5  Recipients or Persons Accessing Personal Data

Images from the video surveillance system are accessible only to authorized CNSC personnel, strictly on a need-to-know basis (for example: security team responsible for site security, management, or any person designated to manage incidents). Technical service providers who maintain the system may, if necessary, access images in a controlled manner and on instruction from CNSC. Images may also be transmitted to authorized third parties to comply with CNSC’s legal obligations, in particular in the event of judicial requisition, or to competent authorities in the event of an incident.
Data from the video surveillance system is not transferred outside the European Union.

3.6  Security of Personal Data

Taking into account the evolution of technologies, implementation costs, the nature of data to be protected and the risks to the rights and freedoms of individuals, CNSC implements all appropriate technical and organizational measures to ensure the security of personal data collected.
These measures include:
•    Access to images reserved exclusively for authorized personnel and subject to a confidentiality obligation;
•    Implementation of logical security measures (authentication, access management) and physical measures (equipment protection);
•    Traceability of access and consultations through logs;
•    Measures to prevent unauthorized access, alteration or loss of recordings;
•    Contractual framework governing service providers and interventions carried out on CNSC’s instruction.

3.7  Rights of Data Subjects

Within the limits and conditions laid down by the GDPR, you have the right to:
•    request confirmation that an image concerning you has been recorded and, if applicable, to receive a copy (subject to respect for the rights and freedoms of third parties);
•    request deletion of images concerning you if they are retained beyond the permitted period or when their processing is unlawful;
•    request restriction of the processing of your image;
•    object to processing for reasons relating to your particular situation, except where compelling legitimate grounds justify continued processing;
•    lodge a complaint with the National Commission for Data Protection (CNPD) or the supervisory authority of your place of residence if, after contacting us, you believe your rights are not being respected. CNPD contact details: 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg.

To exercise your rights or for any questions about the processing of your data, you may contact the CNSC DPO, by electronic means: dpo@coque.lu. To facilitate processing of your request, you may be asked to specify the date, approximate time and location of passage concerned, as well as to provide proof of your identity. Where necessary to protect the rights and freedoms of third parties, certain information may be obscured (for example by blurring) and/or viewing may be offered instead of a copy. CNSC will respond within the timeframes provided for by the GDPR.

Last modified: April 2026