Photo and video recordings
Information on the processing of your personal data
We hereby inform you about the processing of your personal data by DIAL GmbH, Bahnhofsallee 18, D-58507 Lüdenscheid, and your rights pursuant to the data protection law.
Who is responsible for data processing and who is the data protection officer?
The data controller responsible for data processing is:
58507 Lüdenscheid Deutschland
Tel. +49 (0) 2351 5674 0
Fax +49 (0) 2351 5674 410
You can contact our data protection officer at:
progressorg GmbH Höveler Weg 2
Tel. + 49 (0) 2353 9096 31
Fax + 49 (0) 2353 9096 49
Which categories of data do we use as an employer and where do they come from?
We process photo and film recordings which we produce and gather at various occasions.
What are the purposes and what is the legal basis for this data processing?
We produce photo and film recordings in order to document our activities and keep records of our events. We also use these photo and film recordings to report on our events. The image and video recordings may be published: e.g. on our website, on our social media channels, in flyers or advertising brochures, in internal presentations. We will also, as far as is permissible under data protection law, make these available to you upon request. Should we want to process your personal data for a purpose not named above, we will inform you about this in advance. We process your personal data in accordance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG) and all other relevant laws. The following legal bases apply to the production of photo and film recordings and to the publishing of the same:
a) As part of your consent for photo and film recordings (Art. 6(1) (a) GDPR) which you can revoke at any time (explained further below): We obtain your consent for the creation of photo and film recordings if we take portrait and close-up images of individual people. Moreover, in addition to the legal permission explained below, we will always ask for your agreement if doing so does not require an unreasonable amount of effort. This is unfortunately not possible in the case of large events.
b) For the purposes of balancing interests to safeguard our legitimate interests (Art. 6(1) (f) GDPR): Our legitimate prevailing interest in documenting our activities and preserving records includes the production of general and group images at events that do not specifically depict individual people in portrait or close up. This also applies to information about your ethnic origin, religion or health (e.g. skin color, head covering, glasses) that can be gleaned from the photo and film recordings according to Art. 9(2) (e) GDPR.
a) As part of your consent for the publishing of photo and film recordings (Art. 6 (1) (a) GDPR) which you can revoke at any time (explained further below): We obtain your consent for the publication of photo and film recordings in different types of media if we want to publish your portrait and close-up images. Moreover, in addition to the legal permission explained below, we will always ask for your agreement if doing so does not require an unreasonable amount of effort. This is unfortunately not possible in the case of large events.
b) For the purposes of balancing interests to safeguard our legitimate interests in publishing via a concrete medium (Art. 6(1) (f) GDPR in conjunction with subsection 22 and 23 KunstUrhG - German law regulating art and copyright): We only publish photo and film recordings of you without your consent if this is in our overriding legitimate interest in documenting and reporting our activities, which is the case with recordings in which individuals are only "accessories" or where we have taken general or group pictures
Who receives your data?
Within our company, only the person and parties who need your data for the fulfillment of our contractual and legal duties receive your personal data. We do not publish any photos without prior examination. If we have engaged the services of external photographers, we receive the photo data from these service providers. The internal method is as described above. If we publish photo and film recordings on social media channels, the data is transmitted to these channels and also processed by the operators of the social media platforms. We have no influence as to how these operators handle your data.
What data protection rights can you assert as a data subject?
You can request access to the stored data on you using the address above. You can also request the rectification or erasure of your data under certain conditions. You have the right to restrict the processing of your data as well as the right to receive the information provided by you in a structured, accessible and machine-legible format. If you have consented to us processing your personal data via a corresponding declaration, you can withdraw this consent at any time for the future. If we process your personal data on the basis of a legitimate interest (Art. 6(1) para 1, (f) GDPR), you can object to this data processing at any time; in the case of processing for purposes other than advertising, a particular reason is required for your objection - please provide us with this.
This withdrawal or objection does not affect the legitimacy of the data processing performed in the time period before the withdrawal or objection on the grounds of consent or legitimate interest. The withdrawal or objection can generally be submitted without a particular form. Due to evidence requirements, however, we request that you declare the withdrawal or objection via post or e-mail to the contact details provided. Please use the subject "Withdrawal of consent" or "Objection to data processing".
If you withdraw your consent or object to data processing, we will no longer process the personal data concerned and delete the same, unless a legal regulation permits further processing or, in the event of a legitimate objection, we can demonstrate compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms, or which assist in the establishment, exercise or defence of legal claims (Art. 7(21) GDPR, Sec. 14 DSG NRW - Data Protection Legislation of North Rhine-Westphalia). We will delete any photo and film recordings which we have published on our social media channels as soon as we receive your withdrawal or objection and, in accordance with Art. 19 GDPR, will also inform any parties to whom your data has been transmitted (esp. the social media channel providers). Please note here, however, that this does not constitute a definite deletion from the internet, as it cannot be precluded that the files are saved in temporary storage or as screenshots by third parties.
For how long is your data stored?
Photo and film recordings and personal data are stored indefinitely, as this is the only way that we can keep permanent documentation of our activities, also in terms of historical interest.
Right to complain to a supervisory authority
In accordance with Art. 77 GDPR, you have the right to lodge a complaint with the supervisory authority if you believe that the processing of your data has been carried out illegitimately. The address of the supervisory authority responsible for our company is: Landesbeauftragter für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (North Rhine-Westphalia state official for data privacy and information security), Kavalleriestraße 2-4, 40213 Düsseldorf, E-mail: firstname.lastname@example.org. Furthermore, you have the option of contacting the supervisory authority at your usual place of residence.