Notice for people on a monitored site
Video surveillance and safety analytics notice
This site uses its existing CCTV cameras together with OTDMT, a safety analytics system, to detect dangerous situations and prevent accidents. The system observes situations, not people. Faces and vehicle registration plates are removed before any image is stored or shown to anyone.
1. Who is responsible
The operator of the facility you are on is the data controller for the camera images. The operator decides which areas are covered, which safety situations are monitored, who may review the results and how long records are kept. The operator's contact details for privacy matters are displayed at the site entrance and on the operator's own privacy notice.
OTDMT provides the analytics software and operates it on the controller's behalf as a data processor, under a written processing agreement. OTDMT's privacy contact is privacy@otdmt.tech.
2. What is recorded and why
The cameras are the ones the facility already operates. OTDMT reads their video and identifies safety-relevant situations in defined areas, such as pump islands, delivery bays, hazardous-material zones, vehicle lanes and restricted areas. The purposes are:
- preventing accidents, injuries, fire and environmental damage by identifying dangerous situations as they happen;
- meeting the operator's occupational health and safety obligations, including the duty to identify hazards and to train staff;
- learning from recurring situations so that safety training is specific to this site;
- investigating incidents and near misses that have already occurred.
The system is not used for marketing, for measuring individual productivity, for disciplinary monitoring of individual employees, or for identifying customers.
3. How the images are processed
- Inside the facility. Analysis runs on a server located on the premises. Video is not sent to a cloud service and does not leave the site.
- In memory. Live video frames are analysed and then discarded. OTDMT does not create a separate recording of the camera streams.
- Anonymized before storage or display. When a safety event is recorded, the short evidence clip and still image are processed so that faces and vehicle registration plates are blurred before the material is stored or shown on any screen. If anonymization cannot be completed, the material is withheld rather than displayed.
- No facial recognition of the public. The system does not identify customers or visitors and contains no such function. Where the operator has enabled staff identification for safety purposes, it applies only to staff who have given their explicit consent and can withdraw it at any time.
- Human review. Every recorded event is reviewed by an authorised person before it leads to any action. The system recommends; people decide.
4. Lawful basis
The controller relies on the following legal bases:
- compliance with legal obligations in occupational health and safety and in the safe operation of fuel and hazardous-material facilities (GDPR Article 6(1)(c); Turkish Personal Data Protection Law No. 6698, Article 5(2)(ç));
- the controller's legitimate interest in protecting the life, health and property of workers, customers and visitors, which has been assessed against your rights and interests in a data protection impact assessment (GDPR Article 6(1)(f); Law No. 6698, Article 5(2)(f)).
5. Retention
| Record | Kept for |
|---|---|
| Live video frames during analysis | Seconds, in memory only. Not stored. |
| Anonymized evidence of a recorded safety event that is reviewed and closed | 30 days, then deleted automatically. |
| Anonymized evidence linked to an incident under investigation or subject to a legal hold | Until the investigation or legal requirement ends, and no longer than 12 months unless the law requires otherwise. |
| Event records without imagery (class, zone, time, severity, review decision) | 24 months, for safety trend analysis and training records. |
| Access and audit logs | 12 months. |
The controller may set shorter periods. Retention is enforced automatically by the system.
6. Who can see the material
Only authorised people at the operator, such as the health and safety team and site management, can view recorded events, using a named account with role-based permissions. Every view, review decision and configuration change is written to an audit log. OTDMT staff access the system only for maintenance and support, under the processing agreement and the controller's instructions.
7. Sharing and transfers
Camera material is not sold, not used for advertising and not shared with third parties, except where the controller is legally required to disclose it, for example to a competent authority investigating an accident, or where it is needed to defend a legal claim. Video does not leave the facility. Aggregated safety statistics that contain no imagery and no personal data may be used by the operator and by OTDMT to improve safety performance.
8. Your rights
Depending on the law that applies to you, you have the right to:
- be informed about the processing, which this notice provides;
- request access to personal data held about you;
- request rectification or erasure, and object to or request restriction of the processing;
- lodge a complaint with a supervisory authority: the Personal Data Protection Authority (KVKK) in Türkiye, or the data protection authority of your country in the European Union.
Because faces and plates are anonymized before storage, the controller will often be unable to link stored material to an identifiable person. Where a request concerns a specific event, please give the date, approximate time and location so that it can be found.
To exercise your rights, contact the operator using the details displayed at the site. You may also write to privacy@otdmt.tech; OTDMT will forward your request to the controller without delay.
9. Signage and questions
Camera symbols and a short notice referring to this document are displayed at the entrances to monitored areas. Questions about the system may be directed to site management or to privacy@otdmt.tech.
10. Changes to this notice
This notice is reviewed at least once a year and whenever the processing changes materially. The version and effective date appear at the top of the document.
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