25 The video-recorded material may only be viewed, if necessary, by identified and appointed persons in charge and, in any case, may only be stored in a place not accessible to outsiders for a limited period of time (according to the Guarantor, a period of not more than 7 days is appropriate). All these precautions to protect privacy must be adopted by the data controller who, in the case of video surveillance for security purposes, cannot be identified in the lift maintenance company, unless the latter supplies the software and/or in any case has access to the images, even during maintenance. Only in this case, in fact, assuming a different role, would it be bound by specific obligations dictated by privacy legislation. In any case, it is a good idea for the maintenance company, when installing the video camera, to make sure that the administrator has complied or will comply with the above-mentioned rules. If it is true, in fact, that as a rule the company is only involved in the preparation of the accommodations useful for the installation of the cameras in the car and for the placement of the equipment, remaining extraneous to their operation, use and management, it is also true that it, by participating in the implementation of the video surveillance system, could be involved in a different capacity in the event of disputes. Therefore, also from this point of view, it is useful that, before starting work, the company contractually clarifies that its intervention is limited only to the installation or preparation of what is necessary for the installation of the system and obtains a declaration from the administrator on compliance with privacy protection regulations or the commitment to comply with such prescriptions. * Berliri Nucci Veroni Law Firm lawyers The signposts must be placed before or in the vicinity of the camera’s range of action and must be of such a format and positioning as to be clearly visible in all ambient lighting conditions. Each sign, in addition to indicating the existence of the cameras, must contain a simplified information sheet that states: • the identity and contact details of the data controller and, where applicable, its representative (which in the case of condominium lifts is the condominium in the person of the administrator) and of any data processors (those who process personal data on behalf of the data controller); • the purpose of the processing (e.g. security reasons, prevention of vandalism, etc.); • the storage period of personal data; • the possibility for data subjects to exercise their rights under the Regulation by indicating their contact details. Each sign must, however, refer to the full privacy policy indicating where it is available and how it can be consulted. 25
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