Camera Recordings from Trams

Legal basis for the processing of your personal data:

The providing and processing of your personal data is necessary to fulfill the legitimate interests of the Prague Public Transit Company (DPP), in accordance with the provisions of Article 6, Section 1(f) of the General Data Protection Regulation (GDPR).

Personal Data Processed

A visual record (recording) of the physical appearance (face and body) of passengers, vehicle registration license plates and the physical appearance of highway users and other persons in the monitored area in front of and around the tram.

Your personal data is being processed in order to do the following:

Camera recordings are taken to monitor:

  • the interior of the trams (passenger area) and the immediate surroundings of the tram, including the entrance door (hereinafter referred to as the “camera system”),
  • the area in front of the tram (hereinafter referred to as the “accident camera”).

The reasons for the processing personal data through a camera system that monitors the interior of trams and the immediate surroundings of the tram (especially around the door) are the following:

  • acquisition and use of such records for the protection of property and other rights of the Prague Public Transit Company (DPP),
  • acquisition and use of such records for the protection of the property and health of passengers and employees of the Prague Public Transit Company (DPP),
  • acquisition and use of such records for the prevention of vandalism and, at the same time, for the prevention of security risks related to the movement of persons in the transport systems of the Prague Public Transit Company (DPP),

Your personal data is being processed through the accident camera, which monitors the area in front of the tram, for the following reasons:

  • acquisition and use of the record for the protection of property and other rights of the Prague Public Transit Company (DPP) and other authorized parties (drivers, passengers and other participants) in the event of an incident that would qualify as a misdemeanor type of offense, a traffic accident or other type of insurable event.

The reasons for the processing of personal data are meant to, in no way, interfere with the respective privacy rights of passengers or employees of the Prague Public Transit Company (DPP), other than for those reasons, which have been called out above. And, the Prague Public Transit Company (DPP) commits to making sure that any processing of these records for purposes other than those noted above will not take place and recognizes and acknowledges that any such actions would be in direct violation of the provisions of Article 5, Section 1(b) of the General Data Protection Regulation (GDPR) and the provisions of Section 316 of Act No. 262/2006 Coll., the Labor Code.

Recipients or categories of recipients of Personal Data

Personal data may be passed on to third parties (recipients) as required and only for the purposes referenced above.

With respect to the recordings from its camera systems, such recordings will only be made available to the Police of the Czech Republic (and such recording will only be made available on the basis of a specific request for such recording from the Police of the Czech Republic).

With respect to the recordings from the accident cameras, such recordings can be made available to the Police of the Czech Republic, possible administrative authorities and any contractually-related insurance company.

For how long will the company be storing my personal data and what is the criteria being used to determine this period?

Your personal data is generally processed for the time necessary to fulfill the purpose of the processing. The Prague Public Transit Company (DPP) will delete personal data as soon as the purpose for which the personal data was processed ceases to exist.

We process your personal data for the period of time, which is determined to be necessary on the basis of the following criteria:

  • Legal claims of the Prague Public Transit Company (DPP) and third parties: We retain your personal data relevant to the processing of any claim by the Prague Public Transit Company (DPP) or a third party for as long as any claim can be prosecuted by the company and / or by the affected individual or for as long as required under the law. 
  • If your personal data (or camera recording) is needed as evidence in criminal proceedings, it does not fall under the provisions of the General Regulation on the Protection of Personal Data” (GDPR) but is governed by Directive No. 2016/680 of the European Parliament and of the Council and the above-referenced Act.
  • Litigation and other proceedings: Should the processing of your personal data be relevant to any proceedings in which Prague Public Transit Company (DPP) is a party (or intervener), the company will retain your personal data for the entire duration of these proceedings and for the period of any possible subsequent and ancillary proceedings.

Camera recordings for which there is no other reason to save them except to protect the rights of parties involved in some type of legal claim, are only retained for a period of 48 hours. After this time, they are automatically deleted.

Processing Method

Personal data is not made available to anyone except the recipients listed above, and it is only otherwise released on the basis of a legal obligation to do so or in compliance with a high standard of protection.
Personal data is protected by several independent physical and procedural means.
The premises of the tram and the tram depot are sufficiently protected against the intrusion of unauthorized persons. Personal data is stored on a disk of sufficient size, to which only a predetermined group of Prague Public Transit Company (DPP) employees has access. Recordings can only be played back under specifically defined circumstances and conditions. Individual sequences of such records are password protected and encrypted. It is not possible to connect to any of the recording devices using Wi-Fi or a mobile connection. This is done in order to eliminate any possible security risk to such recording through use of a means of remote access. Overall, the Prague Public Transit Company (DPP) has taken and follows a comprehensive range of measures to prevent the loss, destruction or misuse of records by having carefully made an assessment of possible risks.