Personal data processing principles

Personal data processing principles when carrying out video surveillance

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), we inform You about the processing of personal data when carrying out video surveillance (hereinafter in the text – Principles).

Controller

Latvenergo AS, registration number: 40003032949, legal address: 12 Pulkveža Brieža Street, Riga, LV-1230 (hereinafter – Latvenergo AS)

Contact information of the Controller

Legal address: 12 Pulkveža Brieža Street, Riga, LV-1230;

E-mail: info@latvenergo.lv

Contact information of the Data Protection Officer

Address: 12 Pulkveža Brieža Street, Riga, LV-1230;

E-mail: fpda@latvenergo.lv

1. Purposes and legal basis of personal data processing, categories of personal data and processing periods

Purposes of data processing	Legal basis for processing	Categories of personal data	Processing periods
For security at Latvenergo AS premises, in site territories or at sites, for the protection of persons and property*	Processing is necessary for the legitimate interests of Latvenergo AS and third parties (Article 6(1)(f) of the General Data Protection Regulation): to prevent and detect security risks by carrying out video surveillance at sites and the territories adjacent to them for the protection of persons and property, including by using body-worn video cameras	image of the person (appearance, behaviour, actions performed) image of the vehicle, make, State registration number plate time, date and place of the recording of the image of the person and vehicle	video surveillance recordings are processed for no longer than 30 days
to monitor visitor access (video surveillance signs additionally depicting a loudspeaker pictogram)	image of the person with a voice recording during a conversation	video surveillance recordings are processed for no longer than 14 days
for the protection of the legal interests of Latvenergo AS	Processing is necessary for the legitimate interests of Latvenergo AS and third parties (Article 6(1)(f) of the General Data Protection Regulation): to detect and investigate incidents and secure evidence (for example, in order to store personal data for a certain period in the event of a potential dispute so that the dispute can be resolved)	image of the person (appearance, behaviour, actions performed) image of the vehicle, make, State registration number plate time, date and place of the recording of the image of the person and vehicle image of the person with a voice recording during a conversation	If a video surveillance recording shows unlawful conduct or conduct that may help Latvenergo AS or third parties protect their legal interests, the relevant video recording may be retained until the legal interest has been secured (for example, until the day the final court judgment enters into force)
For providing the electric vehicle charging service and ensuring quality control	Processing is necessary: for the performance of contractual relationships in the cases specified in the Terms of Use of the Electric Vehicle Charging Service (Article 6(1)(b) of the General Data Protection Regulation) for the legitimate interests of Latvenergo AS and third parties (Article 6(1)(f) of the General Data Protection Regulation): to ensure and improve the quality of the electric vehicle charging service and/or to monitor the exceeding of the time planned by the data subject (customer) for electric vehicle charging and the provision of the service	image of the person (appearance, behaviour, actions performed) image of the vehicle, make, State registration number plate time, date and place of the recording of the image of the person and vehicle	video surveillance recordings are processed for no longer than 40 days

* For security purposes, video surveillance may use video analytics with artificial intelligence solutions, for example, to monitor the use of personal protective equipment at Latvenergo AS sites and territories, detect falls (injuries) of natural persons and promptly identify various types of security threats.

2. Recipients of personal data

Where a legal basis exists and in compliance with personal data protection requirements, Latvenergo AS may transfer Your Personal Data to the following recipients of Personal Data:

2.1. Latvenergo AS employees and authorised persons to whom Latvenergo AS gives access and whom it has obliged to process Your Personal Data in order to ensure the fulfilment of the above-mentioned Personal Data processing purposes;

2.2. persons related to the provision of Latvenergo AS services and the development of its operations, in order to ensure the fulfilment of the above-mentioned Personal Data processing purposes, including, but not limited to:

providers of information system maintenance services;
providers of guard and security services;
providers of legal services.

2.3. law enforcement authorities, national security authorities, courts, direct State administration authorities and other third parties, on the basis of a written request and an obligation laid down in laws and regulations;

2.4. in certain cases, Latvenergo Group company, if the relevant video recording concerns the property or human resources of the Latvenergo Group company.

Personal Data is not intended to be transferred to recipients outside the European Union or European Economic Area countries.

3. Your rights in relation to the processing of Personal Data

You have the right to:

3.1. access Your Personal Data and receive from Latvenergo AS information about the processing of Your Personal Data by submitting a written request, if the information provided in these Principles does not seem sufficiently comprehensive to You;

3.2. by submitting a written request, request the rectification or erasure of personal data, exercise the rights to data portability and restriction, or object to the processing of Your personal data. In the cases laid down in the General Data Protection Regulation, the Controller may restrict the exercise of Your rights as a data subject, in each specific case justifying its decision with compelling legitimate grounds;

3.3. lodge a complaint with Latvenergo AS, as well as with the Data State Inspectorate (17 Elijas Street, Riga, pasts@dvi.gov.lv), if You believe that Latvenergo AS has infringed Your rights or has not sufficiently protected Your Personal Data. However, before contacting the Data State Inspectorate, we invite You to contact Latvenergo AS.

4. Procedure for submitting requests to exercise Your rights

To exercise all of the above rights, You can use the Latvenergo AS contact information specified in the Principles, stating the following Personal Data in Your request: first name, surname, personal identity number, postal address (if You wish to receive the reply by registered letter) or e-mail address (if You wish to receive the reply by e-mail), as well as providing additional information identifying You (for example, the date, time and place of the video surveillance recording and information describing Your appearance).

We invite You to submit the request in one of the following ways:

send a free-form application electronically to the e-mail address info@latvenergo.lv or fpda@latvenergo.lv, signing the e-mail with a secure electronic signature;
send Your signed free-form application by post to the address: Latvenergo AS, 12 Pulkveža Brieža Street, Riga, LV-1230.

5. Other provisions

Latvenergo AS has the right to make additions to the Principles, making their current version available to You on the Latvenergo AS website.

Policy updated on 30 April 2026.