Video Surveillance Policy

Chapter 1

General Provisions

This Video Surveillance Policy (hereinafter referred to as the "Policy") has been developed in accordance with the Video Surveillance Regulation approved by the Director of BLS Solutions LLC (hereinafter referred to as the "Organization" or "BLS Solutions LLC").

• The approval of this Policy is one of the measures taken by the Organization to protect personal data, as stipulated by Article 17 of the Law of the Republic of Belarus dated May 7, 2021, No. 99-З "On Personal Data Protection" (hereinafter referred to as the "Law").
• This Policy explains to data subjects the purposes of processing their images captured by the Organization's surveillance cameras and outlines the rights of data subjects and the mechanisms for exercising those rights.
• For questions regarding the implementation of the Regulation or legislative requirements in this area, data subjects may contact the person responsible for internal control over personal data processing at:
  • BLS Solutions LLC, Republic of Belarus, 220007, Minsk, Tolstogo Street, 8-2, office 204;
  • Internet address: blsspain-belarus.com.

Chapter 2

Purpose and Legal Basis for Video Surveillance

In BLS Solutions LLC, video surveillance: 4.1. Is carried out in accordance with paragraph twenty of Article 6 and paragraph 1 of Article 17 of the Law to protect processed personal data, information containing legally protected secrets, state secrets, and to control visitor access to the Organization, track employees' working hours, and monitor the storage of documents, material, and financial assets, including the security of documents transmitted to consulates (such as identity documents, travel documents, etc.) and biometric personal data. 4.2. Is not used for:

• The unique identification of individuals depicted in the video recordings;
• Audio recording. 4.3. Surveillance cameras are installed in publicly accessible areas, including:
• Waiting room, VIP room, customer service counters, biometric data collection counters, information desks, other areas in the public and VIP rooms, and evacuation exits. 4.4. Video surveillance is not conducted in other premises of the Organization, including those intended for personal use by employees. 4.5. Video recordings are stored for at least 30 days, after which they are automatically deleted. 4.6. If surveillance cameras capture a situation indicating a criminal offense, administrative offense, or disciplinary misconduct, the storage period for such recordings may be extended by an oral order of the Director of the Organization (or the person performing their duties) for the duration of the investigation and related activities. 4.7. Video recordings cannot be used by employees for personal or other purposes unrelated to their professional activities and are not subject to modification, use, distribution, or provision except as provided by legislative acts.

Chapter 3

Rights of Data Subjects and Mechanisms for Exercising Those Rights

Data subjects have the right to receive information regarding the processing of their personal data by BLS Solutions LLC, including:

• Confirmation of the processing of personal data by the Organization;
• The legal basis and purposes of the personal data processing;
• The data subject's personal data and the source of their receipt;
• Other information as provided by law;
• Information from the Organization about the provision of their personal data processed by the Organization to third parties. This right may be exercised once a calendar year, and the provision of such information is free of charge;
• The right to appeal the actions (inaction) and decisions of the Organization that violate their rights in the processing of personal data in court, in the manner established by civil procedural law. 5.1. To exercise their rights related to the processing of their image captured by the Organization's surveillance cameras, data subjects must submit a written request to the Organization, either in paper form or as an electronic document to the Internet address (blsspain-belarus.com). The request must include:
• The surname, first name, and patronymic (if any) of the data subject, and their residential address;
• The date of birth of the data subject;
• A description of the data subject's request;
• A personal signature (for written requests) or an electronic digital signature (for electronic documents) of the data subject. 5.2. Since the Organization does not use video surveillance for the unique identification of individuals depicted in the video recordings, and the storage period for video recordings is at least 30 days unless otherwise specified in subparagraph 4.6 of paragraph 4 of this Policy, the request must include the date and time period of the recording of the data subject's image, determined within a one-hour interval. 5.3. The Organization will not consider requests from data subjects that do not meet the requirements of subparagraph 5.1 of paragraph 5 of this Policy, including those submitted by other means (telephone, fax, email, etc.). 5.4. For questions regarding the implementation of the Regulation or legislative requirements in this area, data subjects may contact the person responsible for internal control over personal data processing, including by sending an email to: dpo@blsinternational.net with the subject line specified.

Chapter 4

Final Provisions

In all other matters not regulated by this Policy, the provisions of the Organization’s local legal acts and the current legislation of the Republic of Belarus shall apply.

The Organization reserves the right to make changes and (or) additions to this Policy at any time.

This Policy comes into effect upon approval by the Director of the Organization.