“Safety AI” System Privacy Statement

Identity of the Data Controller & Purpose of Processing

The HALCOR Copper and Alloys Extrusion Division of ElvalHalcor SA, having its registered office at Oinofyta Viotia, 62nd km Athens – Lamia National Road, Greece (hereinafter the “Company”), controls your personal data upon entry into the monitored areas, which are indicated by relevant signage, for the purpose of preventing risks against the life, safety and health of employees, subcontractors and visitors, in high-risk areas. It uses an artificial intelligence system (“AI”), which diagnoses potential risks in real time (“Safety AI”).

What & whose personal data are being processed

  • The following personal data are subject to processing, to comply with legal obligations and safeguard own legitimate interests with regards to the protection of the health and safety of individuals:
    • CCTV footage of employees, subcontractors and visitors, taken by a CCTV system upon entering and circulating into areas, assessed as of being objectively high risk, which are monitored by Safety AI
    • In case of an accident, such CCTV data may also include health data, related to the said event or deriving from it
  • We only collect footage, limited to areas where we have assessed that there is an increased likelihood of risk occurrence, due to the nature of these areas and conditions therein.
  • No footage is taken from areas with increased expectations of privacy (e.g. toilets or rest areas)

Who Processes Your Personal Data

Processing is performed by our company and other Viohalco companies or collaborating third parties for supporting SafetyAI and exclusively in order to ensure the successful fulfillment of the aforementioned purposes, through its use.
Personal data is not sold to anyone, not sent abroad or provided to any third party that is not essential in ensuring the aforementioned purposes. Cloud Services may be used in facilities within EU/ EEA.

Protecting your Personal Data

Our company’s intent is to ensure that appropriate precautions exist to safeguard your personal data in any phase or location of its processing. That also includes collaborating parties when used.

Retention of Personal Data

We shall maintain the data as follows:

  • For raw footage produced by the CCTV system, for no more than 15 days, except in the case of a health & safety event within that time period, or in case CCTV also serves additional purposes, i.e. equipment operational assurance or product quality assurance.
  • For footage processed through AI, no data is retained, except in the case of a deviation from safety rules being detected.
  • In case the SafetyAI detects a possible deviation from safety rules, a video footage of approximately 8-12 seconds duration is stored, but without immediately identifiable personal features (facial characteristics), This footage is retained for no more than 15 days, except in the case of a health & safety event having occurred/ being detected within that time period.

However, we may maintain this data further if so mandated by law, or for overriding legitimate interests of HALCOR that may arise until these interests are no longer in effect.

Automated decision-making & profiling

Any potential automated decision-making is limited to the initial diagnosis by SafetyAI on a potential risk against health and safety and the resulting notification of competent personnel. This initial diagnosis may include neglect of safety measures or violation of relevant rules and measures by the data subject. The detection of such neglect or violation may technically temporarily constitute profiling. Said temporary profiling applies only at the specific instant, until recorded footage is anonymised/pseudonymised, in order to be used for any further assessments.
Ιt is noted that:

  • The system does not correlate repeated events that potentially concern the same data subject and is not intended for the creation of a profile for said data subject.
  • We prohibit the use of the system for job performance evaluation, behavioural profiling and personalised risk scoring.
  • The system does not produce legitimate or similarly significant results, without further human intervention.

Your Rights as Data Subjects

You have the following rights:

1. To be informed of the personal data we process and request for a copy,
2. To request the data to be corrected, deleted or to object to the processing of this data or ask for restrictions on its processing.


Note that in some cases:

  • this may lead to our inability to allow your entry and circulation within our premises,
  • the above rights may be subject to certain exemptions, where we may still need to process this data further, based on company’s overriding legitimate interests and legal obligations regarding the protection of the health and safety of individuals.

3. You are entitled to complain to the personal data Supervisory Authority:
Hellenic Data Protection Authority
Web: www.dpa.gr
Email: contact@dpa.gr

Contact us

For any questions, please contact us at (+30) 22620 48856 and privacy@halcor.com