PALERMO FOOTBALL CLUB S.P.A. hereby informs that, pursuant to Regulation (EU) 2016/679 (GDPR), EDPB Provision No. 3/2019, and the applicable national legislation in force, the Company uses a closed-circuit video surveillance system at the premises of the Multi-Purpose Sports Center located in the municipality of Torretta, solely for the purpose of ensuring security, protecting company assets, and preventing unlawful acts.
PURPOSES, LEGAL BASIS, AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
- We inform you that the data will be processed using the following tools:
- IT systems
The data collected are used for the following purposes:
- Collection of evidence;
- Protection of property;
- Protection and safety of individuals;
- Detection, prevention, and monitoring of violations.
The legal basis for the processing of personal data, pursuant to Article 6 of the GDPR, is:
- The pursuit of the legitimate interest of the Data Controller.
The data processing, in compliance with the Workers’ Statute (Article 4 of Law No. 300/1970 as amended by Article 23 of Legislative Decree 151/2015), has been authorized by the trade union agreement signed on 23/10/2025. The video surveillance system will be used in accordance with the Provincial Protocol Agreement on the installation of anti-robbery security systems in workplaces dated 17/07/2012.
The video surveillance system will not be used to carry out remote monitoring of employees, as expressly prohibited by Article 4 of Law No. 300/1970, as amended by Article 23 of Legislative Decree 151/2015.
Pursuant to the Provision of the Italian Data Protection Authority on video surveillance dated 8 April 2010, for the purposes of protecting company assets and ensuring the safety and security of individuals, the consent of the data subjects is not required.
DATA RETENTION PERIOD
- The data retention period is as follows: data are stored for a maximum of 48 hours, except in cases requiring extended retention due to holidays or closure of offices and services, or where it is necessary to comply with a specific investigative request from the Judicial Authority or the Judicial Police.
At the end of the retention period, the images are automatically deleted through overwriting. The application of security measures and compliance with the Provision of the Italian Data Protection Authority on video surveillance dated 8 April 2010 are guaranteed.
CATEGORIES OF RECIPIENTS
- The data collected through the video surveillance system will not be disclosed.
The data may be communicated to third parties contractually linked to the Data Controller exclusively for the achievement of the stated purposes or to comply with contractual or legal obligations, belonging to the following categories:
- External entities appointed for the management/maintenance/administration of the video surveillance system;
- Professionals providing consultancy or legal support to the Company.
Furthermore, the images may be provided to law enforcement authorities and/or judicial authorities upon request.
The individuals authorized to process video surveillance data are:
- Lorenzo Miceli
- Francesco Barresi
- Paolo Vecchia
- Marco Agria
DATA TRANSFERS
- There are no transfers of Personal Data to recipients outside the European Union.
DATA STORAGE AND SYSTEM DETAILS
- The video surveillance system located at the Multi-Purpose Sports Center in the municipality of Torretta consists of 16 Vimar-brand cameras positioned inside the Main Building, the Club House, and at the vehicular entrance of the center.
Data are recorded on a 2TB SATA hard disk installed within a 16-channel N1 NVR recording device, protected by double password authentication for both viewing and querying access.
The management of the video surveillance system is carried out via a control PC located in the control room on the first floor of the Club House. The system allows real-time viewing and recording of images.
Access to the images is permitted only to the Data Controller or individuals specifically authorized in writing. In particular, real-time viewing is allowed only to the authorized persons appointed by PALERMO FOOTBALL CLUB S.P.A., as listed in section 3 of this notice.
The video-monitored areas are clearly marked with appropriate signage.
Regarding retention periods, data are stored for a maximum of 48 hours, except in cases requiring extended retention due to holidays or closure of offices and services, or where it is necessary to comply with a specific investigative request from the Judicial Authority or the Judicial Police. At the end of the retention period, the images are automatically deleted through overwriting.
Compliance with security measures and with the Provision of the Italian Data Protection Authority on video surveillance dated 8 April 2010 is ensured.
RIGHTS OF THE DATA SUBJECT
- Data subjects are granted the rights set out in Articles 15 to 22 of GDPR 679/2016. In particular, the data subject has the right to:
- Access their personal data (Art. 15);
- Request rectification, updating, or completion of data (Art. 16);
- Request erasure of data (Art. 17);
- Request restriction of processing (Art. 18);
- Obtain a copy of the data in a structured, commonly used, and machine-readable format (Art. 20);
- Object to the processing where applicable (Arts. 21 and 22).
These rights may be exercised within the limits where processing is not mandatory under law or regulation.
Requests regarding the exercise of these rights may be sent to the Data Controller at:
info@palermofc.com
If the data subject is not satisfied with the response received, they may lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), headquartered in Rome, Piazza Venezia No. 11, www.gpdp.it.
Citizens of another EU Member State may lodge a complaint with the supervisory authority of their own country.
DATA CONTROLLER
The Data Controller of your personal data is:
PALERMO FOOTBALL CLUB S.P.A.
VAT No.: 06804260823
Tax Code: 06804260823
- Email: info@palermofc.com
- Certified Email (PEC): PALERMOCALCIO@PEC.IT
The Company has appointed as Data Protection Officer (DPO):
Dr. Saito Duilio
Tax Code: STADLU74D13G273Q
- Certified Email (PEC): DPO.PALERMOCALCIO@PEC.IT