Truck drivers




For the Processing of Your personal data, Controller is Aurubis Bulgaria AD, a joint stock company, registered in the Company Register with the Registry Agency under uniform ID code 832046871, having its registered seat and management address in:


Aurubis Bulgaria AD

            Industrial zone

            2070 Pirdop



Aurubis Bulgaria AD is represented by Tim Kurt, Executive Director.



Contact details of the Data Protection Officer


Data Protection Officer, Security and Risk Management department, Aurubis Bulgaria AD, Industrial zone, 2070 Pirdop

Tel.:        +359 7286 2280

Fax:        + 359 7286 2646

E-mail:   d.temelkova(at)



Collection and processing of personal data of truck drivers who enter in Aurubis Bulgaria





















For truck drivers, the company collects and process the following data:

  •  Names;
  • Civil numbers;
  • ID number;
  • Date of birth;
  • Photo;
  • Cell phone number
  • Registration No of truck and trailer;

·         Copies of qualification, driving license  and training certificates, as required by the international ADR Convention on the Transport of Dangerous Goods and others.


Video Surveillance – on the territory of the company are located cameras for 24-hour video surveillance designed for security and operational purposes; on the entrances of the company are located cameras for 24-hour body temperature measurement that aim is to prevent epidemic/ pandemic disease spreading.


Photos - on the territory of the company, truck drivers are shot for proving violations.


The processing of personal data in p. III (1-3) is necessary for the following purposes:

  • Security management – including but not limited to activities related to access control, video surveillance, ensuring security of the premises, assets and information held by the company, and for the purposes of preventing and investigating theft, fraud, abuse, conflict of interest, audits and controls. The processing of personal data for these purposes is based on the legitimate interests of the company to ensure the safety and security of its assets as well as its employees against any possible risks;
  • Operational management – including but not limited to establishment, implementation and management of the business activities of the company, such as loading and unloading activities, communication, administration of insurance claims, health and safety management and others, protection against serious cross – border threats to health. The processing of personal data for these purposes is based on the legitimate interests of the company to manage its material and financial resources and workforce, to mantain business communication with its partners as well as to manage its budget effectively and its expedition schedules ;

·         Compliance with regulatory requirements and settling of legal disputes - including, but not limited to, the International ADR Convention on the Transport of Dangerous Goods, tax, customs, health, commercial and other applicable legislation. The processing of personal data for these purposes is done on the basis of compliance by the company with applicable legal obligations.


Personal data entered into the access control system is processed and kept for up to 3 years.

Video records are processed and stored for up to 2 months of creation in compliance with the Private Security Services Legislation. The video records of sites under the Waste Management Act are processed for up to 1 year.

Photos of truck drivers are processed for a period of 5 years from committing a violation, unless they have become necessary within that period to establish, exercise or protect of any legal claims or administrative proceedings against Aurubis Bulgaria AD. In this case they will be stored until the end of the relevant legal procedure.

Personal data which is processed in case of work accidents, is stored for up to 5 years after the event.


Video records and indicators of body temperature measurements are processed for up to 2 weeks.


Truck drivers provide their personal data to the Company on a voluntary basis. If they do not provide their personal data, the company will not be able to allow them to carry out loading and unloading activities because it will not be able to fulfill its legitimate interests and/ or legal obligations.



The grounds for processing the personal data under p. III (1-3) are based on Regulation (EU) 2016/679 as follows: Article 6 (1) (b) of Regulation (EU) 2016/67 and Article 6 (1) (c) of Regulation (EU) 2016/679 and/ or Article 6 (1) (f) of Regulation (EU) 2016/679 and Article 6 (1) (d) of Regulation (EU) 2016/679, in relation with Article 9 (2) (h) of Regulation (EU) 2016/679 and Article 9 (2) (i) of Regulation (EU) 2016/679.



Collection and processing of Personal Data in other cases


In cases when other companies in the Aurubis Group provide us with the above mentioned data for the above mentioned purposes.



Provision of personal data to third parties


Aurubis Bulgaria AD uses service providers, who process and store personal data ("Personal Data Processors" pursuant to Article 28 of Regulation (EC) 2016/679). In particular, this is applicable to the security company  and other services. These processors work only on contractual basis with Aurubis Bulgaria AD and store and process personal data according to the company's instructions.

In case You contact Aurubis Bulgaria AD on a matter that concerns and/ or is of the competence of another Aurubis Group company, we will provide your information to this company.


If you have entered the premises of the company and subsequently informed us that you have been infected in order to prevent the spread of a pandemic / epidemic disease, this information shall be disclosed to employees of Aurubis Bulgaria AD and employees of contractors who have been in contact with you and respectively may have been infected.


Out of these three circumstances, data will only be provided in individual cases and in a volume that is in accordance with a specific legal obligation of Aurubis Bulgaria AD, as well as in cases where You submitted consent to provide your data.



Truck drivers rights as Data Subject


·         Right to withdraw consent at any time Article 7 (3) of Regulation (EC) 2016/679). As a consequence, the company will not be able to continue processing this data if it was based on consent.

·         Right to request confirmation whether the company processes personal data, and if so, information on the storage and processing (Article 15 of Regulation (EC) 2016/679). In particular, information may be requested about the purposes of processing; categories of personal data; the categories of recipients to whom personal data will be or have been provided; storage period; the right to request correction, erasure and / or limitation of processing, to object to such processing and to lodge a complaint with a supervisory authority; information about the source from which the company have received personal data when it was not collected by the subject; information on the availability of automated decision making (including profiling) and, if applicable, relevant detailed information.

·         Right to request immediate rectification of the personal data (Art. 16 of Regulation (EU) 2016/ 679).

·         Right to request erasure of the personal data, unless its processing is necessary:

1) For exercising the right of freedom of expression and information;

2) For compliance with a legal obligation;

3) For reasons of public interest;

4) For the establishment, exercise or defense of legal claims (Art. 17 of Regulation (EU) 2016/ 679).

·         Right to request restriction of the processing of the personal data if: contest their accuracy; the processing is unlawful; the company does not need the personal data any more, but the data subject require them for establishment, exercise or defense of а legal claim; if the data subject has objected to processing pursuant to Article 21 (1) of Regulation (EU) 2016/ 679 (Art. 18 of Regulation (EU) 2016/ 679).

·         Right to receive the personal data in a structured, widely used and machine readable format or request the transfer of this data to another Administrator (Article 20 of Regulation (EC) 2016/679).


When exercising the right to receive personal data or to transfer it to another Controller, more than once within 24 months, Aurubis Bulgaria AD reserves the right, according to Ch. III, Art. 12 par. 5 (a) of Regulation (EU) 2016/679, to require payment of administrative costs of BGN 20 per set of paper copy and BGN 20 per electronic carrier.


In order to exercise his rights under the above points, the truck driver/ data subject must contact the Data Protection Officer designated by Aurubis Bulgaria AD:


              Address:                   2070. Pirdop, Industrial zone,

              Tel :                         + 359 886 131 999

              E-mail:                      d.temelkova(at)


The truck driver/ Data subject has the right, under Article 77 of Regulation (EC) 2016/679, to lodge a complaint to the Commission for Personal Data Protection (CPDP) by the ways described in the Commission's website. The contact details of CPDP are:


Address:                      1592 Sofia, Prof. Tsvetan Lazarov Blvd. 2

        Fax:                           02 9153525

        E-mail:                        kzld(at)


Aurubis Bulgaria AD will cooperate to CPDP in the handling of such complaints and will comply with all recommendations and/ or instructions issued by the supervisory authority.

The truck driver/ Data subject has the right to lodge a complaint at Aurubis Group Headquarters by sending an email to dataprotection(at) .



Right to object


If the personal data is processed on the basis of a legitimate interest of the company pursuant to Article 6 (1) (f) of Regulation (EC) 2016/67, the truck driver/ data subject has the right to object the processing of these data under Article 21 (1) of Regulation (EC) 2016/679. In this case, the company will not continue the processing of the personal data, unless there are convincing legal grounds for the processing that take precedence over the interests of the data subject, his rights and freedoms or are necessary for the establishment and/ or the defense of legal claims.


If the truck driver/ data subject wants to use the right to object, it is enough to send an email to d.temelkova(at)




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