Rev 01, May 26, 2022

nVent Video Surveillance Notice - Europe

1. Purpose and Scope of nVent’s Video-Surveillance Notice - Europe

For the safety and security of its staff, visitors, buildings, assets and information, nVent operates video surveillance systems (VSS) on select sites.

This video-surveillance notice (i) describes the principles and procedures for the use of VSS at nVent premises in the European Economic Area (EEA), Switzerland and the United Kingdom and the safeguards nVent has in place to protect the personal data of those viewed by the cameras; (ii) describes how to obtain more detailed information; and (iii) explains how you can exercise your rights as a data subject.

2. Who is responsible for the video surveillance?

The controller of your personal data is the nVent entity managing the nVent building which you are visiting. Contact details of the controller are posted on the video-surveillance signage on site. A list of nVent group companies can also be found here

3. Which areas are under surveillance?

The VSS covers select nVent premises. These are clearly marked with the required signage. The amount and location of cameras is limited to the number necessary to achieve the purpose of the surveillance.

Cameras are usually mounted in several locations on nVent premises including main entries, exits and emergency exit points, entrance to secured areas, lobbies, corridors, parking facilities, warehouses, loading docks and the buildings’ surroundings where necessary. These may include transition areas for vehicle access and public grounds in the immediate vicinity of nVent buildings.

The location of the cameras has been carefully reviewed to ensure that the monitoring of areas that are not relevant for the intended purposes is limited to those that cannot be avoided and that the rights to privacy do not outweigh nVent’s interests to perform video-surveillance

4. What personal data is collected, and by which means?

The VSS records digital images in the areas under surveillance indicated in Section 3, as well as the corresponding time, date and location. The systems do not record sound or voice. All cameras activated within the system may operate 24 hours a day, seven days a week. We may combine fixed, domes, pan/tilt, 360 degree and/or zoom cameras, thermal imaging technology, auto-track functionality and live video monitoring.

We use camera lenses, zoom factors and masking capabilities in accordance with the purpose, reducing the identification capabilities to the degree necessary; the access to the system and the footage are password protected and logged.

Where required by law, the operation of the VSS and the used equipment has been subject to a data privacy impact assessment and checked with the competent supervisory authority.

5. Purpose and legal basis of the surveillance

nVent has legitimate interest to operate the VSS for the purpose of

• access control,
• safety, security and integrity of buildings, assets and information of nVent staff, contractors and visitors on nVent premises against incidents of fire, sabotage, theft or physical assault.
• preventing, deterring, and if necessary, investigating unauthorized physical access, including unauthorized access to secure premises and protected rooms, IT infrastructure, or operational information;
• health and safety requirements and procedures.

You can at any time object to nVent's use of your personal data as set forth in this section by sending an email to [email protected]. nVent will then carefully review your objection and cease further use of the relevant information, subject to nVent's compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if nVent requires the information for the establishment, exercise or defense of legal claims.

In addition, nVent can use your personal data based on a legal obligation to support the rightful and valid requests of public authorities to support an investigation.

6. Who has access to the footage and to whom is it disclosed?

Access to the recordings and live video is limited to a small number of clearly identifiable individuals on a need-to-know basis.

• Access rights

nVent specifies the purpose and extent of access rights to the VSS. In particular, it limits who has the right to view the footage in real-time; view the recorded footage; access to the technical infrastructure, perform maintenance or programming activities on the system, copy, download, delete or alter any footage.

External providers tasked with the maintenance and administration of the VSS, might have access to the system, for the necessary time to perform system’ maintenance, remediation and administration activities.

All persons who have access to the VSS including the recordings are required to maintain its confidentiality and keep current with applicable data privacy, data security, and confidentiality requirements arising from the video surveillance activities. They are required to attend adequate training in the care, protection, and handling of the data.

• Transfers and disclosures

VSS system recordings as well as other personal data in our access or parking systems may be shared with certain third parties to fulfil the purposes defined in Section 5 above. As part of a global group of companies operating internationally, nVent has affiliates and third-party service providers outside of the EEA, Switzerland or the United Kingdom and may transfer your personal data to these countries. For more information on our procedures around transferring data you may refer to our Privacy Statement.

Your personal data may be shared with:

1. Companies within the nVent Group as this is a global organization with global security obligations including but not limited to those carrying out a formal internal nVent investigation, in the context of a formal administrative inquiry or disciplinary procedure conducted within nVent in compliance with nVent policies and local laws and regulations.
2. Third-party service providers, including contracted security agencies that are contracted to provide security services or maintenance, and legal counsel.
3. nVent legal or local or federal law enforcement agencies, as the result of any corporate criminal or other security investigations.

7. How long do we keep the data?

Usually the footage is stored for a maximum period of 7 days and is then overwritten. Footage recorded in high-risk areas (e.g. material storage, metal scrap containers, dangerous machinery, loading docks) to prevent theft and injury) is stored for a maximum of 30 days and is then overwritten.

If the video surveillance recording is required for the investigation of an incident to assert or defend against legal claims, the relevant footage is quarantined and can be retained for as long as necessary for the specific investigation or settlement of the claims in question in line with applicable law. Their retention is documented and the need for retention is to be reviewed periodically.

8. How do we provide information about the video surveillance activities?

 To provide you with the adequate information about the video surveillance, we follow a multi-layer approach:

1. We provide on-the-spot notices close to all areas under surveillance and all entry points, including car park entrances, in order to alert the public of the video surveillance and provide essential information about the data processing and a QR Code to access this notice
2. Printouts of this video-surveillance notice are also available from [email protected] or the local front desk or your contact person at nVent upon request.

9. Your rights regarding your personal data

 Applicable data protection laws may provide you with certain rights regarding our processing of your personal data. Specifically, these laws may provide you the right to access and update your personal data, restrict our processing of your personal data, withdraw your consent to our processing of your personal data (when applicable), and the right to have your data erased. You also have the right to lodge a complaint with supervisory authorities if you believe your rights have been violated. For further information about your rights and contact details of nVent and the responsible supervisory authority and data protection officer, please see nVent’s Data Privacy Statement or contact [email protected].