European Data Protection Board releases New GDPR Guidelines on CCTV Surveillance

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The European Data Protection Board (‘EDPB’), which was established just over a year ago with the introduction of the General Data Protection Regulation (‘GDPR’), has recently made available for public consultation its Guidelines on the processing of personal data through video devices (‘the Guidelines’), which includes not just CCTV, but also dashcams, private security cameras and mobile phone cameras.

According to the EDPB, these Guidelines only concern video surveillance wherein personal data, as understood by the GDPR, are actually being processed. Therefore, the surveillance must include information that relates to an identified or identifiable natural person (i.e. a ‘data subject’), such as footage of a person’s face, name tag, or other distinguishing characteristics that render them identifiable (e.g. unique tattoos or birthmarks). Personal data, in any but especially in this context, would also include car license plates, identification documents and most notably, biometric data.

The departure point for setting up any kind of video surveillance system should always be an assessment of whether such a system is needed in the first place. The Guidelines suggest considering alternatives wherever possible, depending of course, on the purpose in question.

If the camera is going to be installed for security purposes, the data controller, i.e. the person who will be responsible for the video footage that would be collected, should consider what other measures may be implemented instead of a camera system, which measures would be less intrusive on individuals’ rights to privacy and data protection. For instance, one should consider whether reinforced walls and glass, better locks, better lighting or hiring security guards would have the same effect.

Furthermore, any installed cameras should only record those areas that need to be monitored. The typical example provided by the EDPB is that of a shop with a camera installed outside to monitor the entrance to the shop and/or the shop windows, to protect against theft and vandalism. Wherever possible, those cameras should not also monitor the pavement or the road outside, since that would mean that personal data of persons who simply pass by and never even enter the shop are being processed, which would exceed the purpose of installing such cameras i.e. security. Hence, the principle of data minimization – only collecting that data which is strictly necessary – as enshrined by the GDPR, plays a key role in video surveillance.

Another consideration should be whether the persons that will be recorded as a result of the installation of the video surveillance system, would reasonably expect to be recorded in that particular instance. For instance, the Guidelines opine that at the workplace, an employee would in most cases not likely expect to be monitored by their employer, whilst a visitor at a bank or at a jewellery store would be more likely to expect that they would be monitored due to the increased need for security. This is not to say that video surveillance cannot take place when an individual does not always expect it, but there must be even greater transparency and information provided to the recorded data subject in those instances where they are less likely to expect such recording.

CCTV Surveillance – leaders in designing and deploying advanced CCTV solutions

CCTV Surveillance delivers both the advanced products and the set of skills required to match the customer’s exact requirements, while also keeping well within the budget limits. Moreover, our latest-generation digital HD video cameras can be installed in virtually any location and offer very good quality, high-resolution images, even in low-light conditions.

The range of infra-red cameras we work with also enables great visibility during night-time, an increasingly popular feature within the CCTV segment. Plus, beside the actual cameras and infrastructure, our lineup also includes a range of digital video recording solutions and control software, designed to help users easily review CCTV footage, at the best possible quality.

It’s also worth mentioning that all of our products are fully compliant with the UK Police Requirements, and we’re also constantly updated on the latest legal requirements in this field, including the new code of practice announced by the Home Office.

If you’d like to find out more about the range of products provided by CCTV Surveillance, just contact our dedicated product team, they’ll be more than happy to answer all of your questions and queries.

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