Video Surveillance Policy

CHAPTER 1. GENERAL PROVISIONS

This Policy has been developed to explain to personal data subjects, who fall within the coverage areas of CCTV cameras installed in the visa center, the purposes of processing their images and voice recordings, as well as to reflect the rights of personal data subjects in this regard and the mechanisms for exercising them.

The Policy is published in open access on the websites blsspainbelarus.by, blsslovakiavisa.by (hereinafter – Website, Websites), and is also available for review on the information board of the visa center.

Video surveillance is carried out on the basis of paragraph twenty of Article 6 of the Law of the Republic of Belarus dated 07.05.2024 No. 99-Z 'On Personal Data Protection', the Law of the Republic of Belarus dated 08.11.2006 No. 175-Z 'On Security Activities in the Republic of Belarus', the Labor Code of the Republic of Belarus, and is performed using open CCTV cameras on a round-the-clock basis.

This Policy explains to personal data subjects who fall within the recording areas of the visa center’s CCTV cameras the purposes of processing their images and voice recordings, as well as reflects the rights of personal data subjects arising in this regard and the mechanisms for their implementation.

Contacts of BLS Solutions LLC:

Address: Republic of Belarus, 220007, Minsk, 8-2 Tolstoy St., office 204;

E-mail: info.minsk@blshelpline.com;

Phone: +375 (44) 732 23 39.

CHAPTER 2. PROCEDURE AND PURPOSES OF CCTV IMPLEMENTATION

2.1. BLS Solutions LLC conducts video surveillance in the visa center premises located at: Minsk, 8-2 Tolstoy St., office 204, for the following purposes:
- Ensuring public order, including the prevention, detection, and suppression of offenses;
- Protection of individuals (visitors, employees), documents, material assets, and other property;
- Controlling visitor access to the visa center;
- Ensuring performance and labor discipline.

2.2. In BLS Solutions LLC, video surveillance is conducted around the clock using open CCTV cameras. The cameras are located in publicly accessible places in the following areas: the visitor waiting area, VIP lounge, customer service counters, biometric data collection counters, information desks, and other areas in the public and VIP zones, as well as emergency exits.

2.3. BLS Solutions LLC informs personal data subjects of video surveillance in the visa center by placing warning information signs.

2.4. Technical maintenance of the CCTV system of BLS Solutions LLC is carried out with the involvement of a third-party organization – Molproektmontazh LLC (address: Minsk region, Molodechno, 2V Metallistov St., office 6) on the basis of a contract. Molproektmontazh LLC holds a license dated 09.04.2021 No. 33030/37210000067058 for carrying out design, installation, adjustment, and technical maintenance of security equipment and systems. Molproektmontazh LLC does not process personal data when carrying out technical maintenance of the CCTV system.

BLS Solutions LLC does not use the CCTV system:
- In premises intended for personal needs and rest of employees;
- For recording the actual working hours of employees of BLS Solutions LLC;
- For unique identification of persons who fall within the coverage of CCTV cameras.

BLS Solutions LLC uses 3 CCTV cameras with audio recording function: one in the general access area, one in the VIP lounge, and one in the biometric data submission zone. They are located in customer service areas for the purposes of monitoring and improving the quality of service, as well as resolving disputes (conflict situations).

BLS Solutions LLC informs personal data subjects of CCTV with audio recording by placing additional warning signs in the areas where such surveillance is conducted.

The storage period of video recordings is 57 days, after which they are automatically deleted. In case of possible recordings indicating disciplinary offenses, administrative offenses, or crimes, by oral instruction of the director, regional manager, deputy director for security, administration and legal work (or persons acting on their behalf), the retention period may be extended for the duration of the relevant measures provided by the legislation of the Republic of Belarus.

Access rights to video camera recordings are restricted for employees of BLS Solutions LLC in accordance with their duties. Access to view video recordings is prohibited except for the director, regional manager, deputy director for security, administration and legal issues, personal data protection officer, system administrator, and employees of the authorized organization carrying out technical maintenance of the CCTV system in the presence of an authorized representative of BLS Solutions LLC.

Access to personal data, including CCTV recordings, is carried out in accordance with the Regulation on the procedure for access to personal data, including those processed in the information system, approved by the director of BLS Solutions LLC.

Employees of BLS Solutions LLC are prohibited from using video recordings for personal or other purposes not related to their duties. Recordings are not subject to alteration, use, dissemination, or provision, except as provided for by law.

BLS Solutions LLC has the right to use CCTV recordings as evidence in civil, criminal, and administrative proceedings to confirm the fact(s) of unlawful acts, as well as to establish other circumstances subject to proof.

Information recorded by the CCTV system in the visa center may be provided to state authorities (organizations) only on the basis of a written request in cases provided for by the legislation in force.

CHAPTER 3. RIGHTS OF PERSONAL DATA SUBJECTS AND THEIR IMPLEMENTATION

Personal data subjects have the following rights:

3.1.1. The right to obtain information regarding the processing of personal data, including:
- The name and location of BLS Solutions LLC;
- Confirmation of the fact of processing of personal data by BLS Solutions LLC;
- The list of processed personal data and the source of its receipt;
- Legal grounds and purposes of personal data processing;
- The period for which consent to personal data processing is given;
- The name and location of the authorized person(s), if the processing of personal data is entrusted to such person(s).

3.1.2. The right to obtain information about the provision of personal data to third parties. The personal data subject has the right to receive such information from BLS Solutions LLC once per calendar year free of charge. Within 15 calendar days of receiving a request, BLS Solutions LLC shall provide information on what personal data and to whom it was provided during the year preceding the request, or inform of the reasons for refusal.

3.1.3. The right to appeal actions (inaction) and decisions of BLS Solutions LLC related to personal data processing. If the personal data subject believes that the processing of their personal data is being carried out in violation of the legislation of the Republic of Belarus, they may submit a complaint to the National Center for Personal Data Protection of the Republic of Belarus. Complaints are considered in accordance with the procedure established by the legislation on appeals of citizens and legal entities.

To exercise one or more of the above rights, the personal data subject must submit a written application to BLS Solutions LLC in one of the following ways:
- In writing (by courier, mail, or in person) to the address: Republic of Belarus, 220007, Minsk, 8-2 Tolstoy St., office 204 (2nd floor);
- In the form of an electronic document containing the personal data subject’s electronic digital signature, to the email address info.minsk@blshelpline.com.

3.3. The application must contain: surname, first name, patronymic (if any), date of birth, residential (or stay) address, a statement of the essence of the request, and the personal signature or electronic digital signature of the personal data subject.

3.4. The response to the application shall be sent in the form corresponding to the form of submission, unless otherwise specified in the application.

3.5. The personal data subject has the right to request assistance in exercising their rights from the person responsible for internal control over the processing of personal data in BLS Solutions LLC or by sending an email to alexander.shtelmakh@blsinternational.net.

CHAPTER 4. FINAL PROVISIONS

BLS Solutions LLC has the right, at its own discretion, to unilaterally amend and/or supplement the provisions of this Policy without prior notice to personal data subjects by publishing a new version of the Policy on the Website.

Issues related to the processing of personal data not addressed in this Policy are governed by the legislation of the Republic of Belarus.

This Policy shall enter into force upon approval by the director of BLS Solutions LLC.