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Personal data protection

Personal data protection

On 25 May 2018 acquired force the EU Regulation of the European Parliament and of the Council (EC) No.: 2016/679 as of April, 27 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) (hereinafter referred to as “GDPR”) and Act No.: 18/2018 Coll. Z. z. on personal data protection as amended.

Slovenské elektrárne respects protection of your privacy and appreciates your trust, that you put into us when we process your personal data. We have implemented all appropriate security measures in order to protect your personal data (of technical, organisational and other type) and processes for the control of their continuous compliance and sufficiency. We also regularly update security measures and perform inspections, so that we prevent unpermitted access to personal data or unauthorized manipulation with the data.

Definitions of Basic Terms

Personal data shall mean any information related to the identified or identifiable natural person; the identifiable person is a person, who can be identified directly or indirectly, in particular by reference to identifier - name, identification number, location data, on-line identifier, or reference to one or more elements, which are specific for physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

Personal data processing shall mean any operation or set of operations with personal data or personal data file, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, sorting, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of data.

A Data Subject is any natural person whose personal data are processed. Data subjects, whose personal data are being processed at Slovenské elektrárne environment, are mainly in-house employees and their family members, persons employed based on a temporary work contract, job applicants, contractors’ employees, visitors, etc.

Controller shall mean everyone, whether alone or jointly with others, who determines the purposes and means of the processing of personal data and processes personal data on own behalf; the controller is company Slovenské elektrárne.

Processor shall mean everyone, who processes personal data on behalf of the controller based on a written contract or agreement.

Observing principles of personal data processing

Slovenské elektrárne, as a controller, define the purpose, conditions, and means of personal data processing, while observing principles of personal data processing defined in the Regulation. Personal data shall be:

processed lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness, and transparency”)

collected for specified, explicit and legitimate purposes (“limiting the purpose”);

adequate, relevant and limited to what is necessary in relation to the purposes, for which they are processed (‘data minimisation’);

accurate and, where necessary, kept up to date (‘accuracy’);

kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (“storage minimisation”);

processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)

Lawfulness of personal data processing

Personal data processing at Slovenské elektrárne is performed based on one of the following legal basis:

a contract with a data subject – data processing is necessary for performance of a contract, where a contracting parties is the data subject, or in order to take measures before concluding a contract based on a data subject’s request;

performance of a legal obligation of the controller – processing is necessary for performance of a controller’s obligation defined by special law (SR or EU legislation);

legitimate interests of the controller – processing is necessary for the purposes of controller’s legitimate interests;

data subject’s consent – if a data subject expressed their consent with processing their personal data for one or more specific purposes.

Exercising data subject´s rights

The right of access to personal data
1.
As a data subject, you shall have the right to obtain from Slovenské elektrárne, as from the data controller, confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information:
a.
purposes of processing;
b.
data subjects categories;
c.
recipients or recipient categories, to which the personal data will be provided, particularly recipients in third countries or international organisations;
d.
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e.
the existence of the right to request from Slovenské elektrárne, as from the data controller, rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
f.
the right to lodge a complaint with a supervisory authority;
g.
if the personal data was not provided by you, as a data subject, any available information as to their source;
h.
Existence of automated decision-making, including profiling [art. 22 (1 and 4) of the general Data Protection Regulation] and in such cases meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you as a data subject.
2.
Where personal data are transferred to a third country or to an international organisation, you shall have the right to be informed of the appropriate safeguards relating to the transfer [art. 46 or the General Data Protection Regulation].
3.
Slovenské elektrárne, as a data controller, shall provide a copy of the personal data undergoing processing. If you, as a data subject, ask for any futher copies, Slovenské elektrárne, as a data controller, may charge a reasonable fee based on administrative costs. If you, as a data subject, have made a request via electronic means, the information will be provided using common electronic form, unless otherwise requested by you.
4.
The right to obtain a copy referred to in the paragraph 3 shall not adversely affect the rights and freedoms of others.
The right to rectification
As a data subject you have right to request Slovenské elektrárne, as a data controller, to rectify incorrect personal data related to you without undue delay. Taking into account the processing purpose, you, as a data subject, shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
The right to erasure (the right to forget“)
1.
As a data subject, you shall have the right to obtain from Slovenské elektrárne, as from the data controller, the erasure of personal data concerning you without undue delay and the data controller shall have the obligation to erase your personal data without undue delay where one of the following grounds applies:
a.
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b.
you, as a data subject, withdraw your consent, based on which the personal data processing is based [as per art. 6 (1,a) or art. 9 (2,a) of General Data Protection Regulation] and where there is no other legal ground for the processing;
c.
you, as a data subject, object to the processing [art. 21 (1) of the General Data Protection Regulation] and there are no legitimate grounds for processing, or, as a data subject, you object to the processing for purposes of direct marketing [art. 21 (2) of the General Data Protection Regulation];
d.
the personal data have been unlawfully processed;
e.
the personal data have to be erased for compliance with a legal obligation in Union or Member State law, to which Slovenské elektrárne, as a data controller, is subject;
f.
the personal data have been collected in relation to the offer of information society services [art. 8 (1) of the General Data Protection Regulation].
2.
If Slovenské elektrárne, as a data controller, has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers, which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
3.
Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
a.
for exercising the right of freedom of expression and information;
b.
for compliance with a legal obligation which requires processing by Union or Member State law to which Slovenské elektrárne, as a data controller, is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in Slovenské elektrárne, as a data controller;
c.
for reasons of public interest in the area of public health [art. 9 (2) h) and i) as well as art. 9 (3) of the General Data Protection Regulation];
d.
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes [in accordance with Article 89 (1) of the General Data Protection Regulation] in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
e.
for the establishment, exercise or defence of legal claims.
The right to the restriction of processing
1.
As a data subject, you have right to have Slovenské elektrárne, as a data controller, restrict data processing, where any of the following grounds applies:
a.
as a data subject, you contest the personal data accuracy for a period allowing to Slovenské elektrárne, as a data controller, to verify the accuracy of the personal data;
b.
the processing is unlawful and you, as a data subject, oppose the erasure of the personal data and request the restriction of their use instead;
c.
Slovenské elektrárne, as a data controller, no longer needs the personal data for the purposes of the processing, but you require the data for the establishment, exercise, or defence of legal claims;
d.
as a data subject, you have objected to processing (pursuant to Article 21 (1) of the General Data Protection Regulation) pending the verification whether the legitimate grounds of Slovenské elektrárne, as a data controller, override your legitimate grounds.
2.
Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defence of legal claims, or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3.
You, as a data subject, who has obtained restriction of processing pursuant to paragraph 1, shall be informed by Slovenské elektrárne, as a data controller, before the restriction of processing is lifted.
The right to personal data portability
1.
As a data subject, you shall have the right to receive the personal data concerning you, which you have provided to Slovenské elektrárne, as to a data controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller without hindrance from Slovenské elektrárne, as a data controller, to which the personal data have been provided, where:
a.
the processing is based on consent [art. 6 (1) (a) or art. 9 (2) of the General Data Protection Regulation], or on a contract [art. 6 (1,b) of the General Data Protection Regulation]; and
b.
the processing is carried out by automated means.
2.
In exercising your right to data portability pursuant to paragraph 1, you, as a data subject, shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
3.
The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to the right to be forgotten [Article 17 of the General Data Protection Regulation]. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
4.
The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
The right to object
1.
You, as a data subject, shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, which is done in order to execute a task in public interest or in exercise of public authority entrusted to Slovenské elektrárne, as a data controller, or based on legitimate interests pursued by Slovenské elektrárne, as a data controller or by a third party [Article 6 (1) (e) or (f) of the General Data Protection Regulation], including objecting against profiling based on those provisions. Slovenské elektrárne, as a data controller, shall no longer process the personal data unless Slovenské elektrárne demonstrate compelling legitimate grounds for the processing, which override your interests, rights, and freedoms, or grounds for establishment, exercise or defence of legal claims.
2.
Where the personal data are processed for direct marketing purposes, as a data subject, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3.
If you, as a data subject, object to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes.
4.
At the latest at the time of the first communication with you, as with a data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to your attention and shall be presented clearly and separately from any other information.
5.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you, as a data subject, may exercise your right to object by automated means using technical specifications.
6.
Where personal data are processed for scientific or historical research purposes or statistical purposes [Article 89 (1) of the General Data Protection Regulation], you, as a data subject, on grounds relating to your particular situation, shall have the right to object to processing the personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

If the personal data processing is based on the consent, the data subject shall have the right to withdraw their consent any time, and processing of their personal data shall be terminated without undue delay.

The contact point for handling any requests and representing Slovenské elektrárne, in relation to data subjects, in relation to all and any questions related to personal data processing and exercising their rights shall be the data protection officer (dpo@seas.sk).

Apart from the above mentioned rights, in relation to personal data processing, you have right to lodge a complaint with a supervisory authority, which is The Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27, Slovak Republic.

Handling requests of data subjects

Please, contact us in electronic form by writing an e-mail to the data protection officer: dpo@seas.sk; or send us your requests in a form of a letter sent to address:

In order to prevent unwanted disclosure and/or provision of information to an unauthorized person, you may be asked to provide additional information necessary to confirm the identity of the applicant.

Slovenské elektrárne, a.s.
Zodpovedná osoba / Data Protection Officer
Mlynské nivy 47
821 09 Bratislava
To speed up the processing of your request as a data subject, please use this form and follow the instructions therein.

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Requests are usually processed in writing as a personal delivery, no later than one month from the delivery of the request. In the case of a complex request requiring more time or technical complexity of processing, or due to supplementing the information necessary to assess and process the request, the deadline can be extended by another two months; you will be informed of such an extension of time, along with the reasons for the extension.
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