SAP Global Physical Security 

Video Surveillance installations at the SAP premises in Finland

Video surveillance cameras (also known as closed-circuit televisions, or CCTV) are directed at viewing and/or recording the images of individuals to ensure an adequate level of security for and at a company´s premises in preventing and/or investigating break-ins, destruction, or other malicious activities.   

The surveillance cameras are installed:

• at the various entry and exit points of the SAP buildings;

• at security relevant areas in the SAP buildings; 

• at parking entrances or parking areas located at the SAP Campus; 

• at the outer area of the SAP buildings within SAP Campus.

All locations where your personal data may be captured are clearly marked by warning signs.

 

Who is the data controller?

The data controller for video surveillance is identified as the appropriate legal entity for respective SAP Finland locations.   The data protection officer can be reached at privacy@sap.com.

Depending on the specific location, this will include one of the following legal entities:

• SAP Finland Oy, Keilasatama 5, 02150 Espoo, Finland
  

 

What personal data does SAP collect?

If you move about SAP´s campus or access SAP´s premises, we collect your images via video surveillance cameras, consisting of a recording of your activities except sound or voice In addition, we collect a picture of your license plate in the parking areas (your "personal data").

 

Why does SAP need your personal data?

SAP processes your personal data in order to ensure an adequate level of security for and at SAP´s premises. 

This process allows SAP to provide you with access to SAP facilities and to ensure the security and safety of all SAP employees, suppliers, visitors, and assets across all global SAP locations. This allows SAP to comply with statutory obligations, including identification verification prior to or during access to any SAP-owned or leased facility.

Although providing personal data is voluntary, without your personal data, SAP cannot provide you with access to SAP-owned or leased facilities.

 

How long does SAP store my personal data?

SAP will store your personal data for a period of maximum 72 hours. If the video surveillance recording is required for the investigation of an incident it can be kept for as long as necessary to conclude the investigation. 

SAP will also retain your personal data for additional periods if it is required by mandatory law to retain your personal data longer or where your personal data is required for SAP to assert or defend against legal claims, SAP will retain your personal data until the end of the relevant retention period or until the claims in question have been settled. 

 

Who are the recipients of my personal data and where will it be processed?

Your personal data will be passed on to the following categories of third parties to process your personal data: 

• Companies within the SAP Group, as this is a global organization with global security obligations

• Third-party service providers, including contracted security agencies that are contracted to provide security services at SAP

• SAP legal or local or federal law enforcement agencies, as the result of any corporate criminal or other security investigations
  

As part of a global group of companies operating internationally, SAP has affiliates (the “SAP Group”) and third-party service providers outside of the European Economic Area (the “EEA”) or from a region with a legal restriction on international data transfers and will transfer your personal data to countries outside of the EEA. If these transfers are to a country for which the EU Commission has not issued an adequacy decision, SAP uses the EU standard contractual clauses to contractually require that your personal data receives a level of data protection consistent with the EEA. You can obtain a copy (redacted to remove commercial or irrelevant) of such standard contractual clauses by sending a request to privacy@sap.com. You can also obtain more information from the European Commission on the international dimension of data protection from the European Commission.

 

What are your data protection rights?

At any time, you can request from SAP: access to information about which personal data SAP processes about you and the correction or deletion of such personal data. Please note that SAP can or will delete your personal data only if there is no statutory obligation or prevailing right of SAP to retain it. 

Furthermore, you can request from SAP that SAP restricts your personal data from any further processing in any of the following events: (i) you state that the personal data SAP has about you is incorrect, subject to the time SAP requires to check the accuracy of the relevant personal data, (ii) there is no legal basis for SAP processing your personal data and you demand that SAP restricts your personal data from further processing, (iii) SAP no longer requires your personal data, but you state that you require SAP to retain such data in order to claim or exercise legal rights or to defend against third-party claims, (iv) in case you object to the processing of your personal data by SAP based on SAP’s legitimate interest (as further set out below), subject to the time required for SAP to determine whether it has a prevailing interest or legal obligation in processing your personal data.

Please note, however, that SAP can or will delete your personal data only if there is no statutory obligation or prevailing right of SAP to retain it.

Please direct any requests to exercise your rights to SAP-Physical-Sec-Privacy@sap.com.

 

How will SAP verify requests to exercise data protection rights?

SAP will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise.  When feasible, SAP will match personal data provided by you in submitting a request to exercise your rights with information already maintained by SAP. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by SAP.  

SAP will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law. 

 

What are my rights to lodge a complaint?

If you take the view that SAP is not processing your personal data in accordance with the requirements in this Privacy Statement or under applicable data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live or with the data protection authority of the country or state where SAP has its registered seat.

 

Why does SAP need to use my personal data and on what legal basis is SAP using it?

SAP can use your personal data based on its legitimate interest (Article 6 para. 1 lit. f GDPR) as follows: 

• to control access to SAP´s campus and premises; 

• to ensure adequate security for and at SAP´s campus and premises;  

• to ensure the safety of SAP employees and visitors SAP´s campus and premises;  

• to prevent, deter, and if necessary, investigate unauthorized physical access, including unauthorized access to secure premises and protected rooms, IT infrastructure, or operational information; 

• to prevent sabotage, theft and material damage.  
  

You can at any time object to SAP’s use of your personal data as set forth in this section by sending an email to SAP-Physical-Sec-Privacy@sap.com. In this case, SAP will carefully review your objection and cease further use of the relevant information, subject to SAP’s compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if SAP requires the information for the establishment, exercise or defense of legal claims.  

In addition, SAP can use your personal data based on a legal obligation (Article 6 para. 1 lit. c GDPR) to support the rightful and valid requests of public authorities for support in an investigation.