New ÚOOÚ methodology on cameras

On 8 February 2024, the Office for Personal Data Protection ("OPPD") issued a new methodology on CCTV systems, which provides administrators with comprehensive guidance on how to navigate the obligations.  

The methodology is divided into three parts: 

  • The first part explains how the methodology itself was developed and how to use it. 
  • The second part deals with a detailed description of the camera system from a technical point of view, including the requirements for camera systems and certain parameters such as camera frame sizes, lighting conditions, reflections, obscuration, etc.  
  • The third part is the key part of the methodology, where the various obligations under the GDPR are discussed and specific guidelines are offered on how to use the camera system correctly. 

Below are some important points from the methodology.  

The principle of minimisation: the controller should carefully assess the number and location of cameras, the recording settings, the recording mode and the retention period of recordings in order to minimise the processing of personal data. 

Retention period: The basic retention period should be 72 hours, with any longer period being justified and properly explained by the controller. 

Legitimate interest: The controller should satisfy certain aspects of legitimate interest, including the importance of the processing of personal data, the necessity and consequences of the processing and respect for the rights of the data subject. 

Balancing test: the DPO recommends that controllers undergo a balancing test, which includes a description of the existence of a real threat, an assessment of the alternatives, an evaluation of the necessity of the chosen option and an assessment of the adequacy of the processing of personal data. 

If you require further information or assistance in implementing this methodology, please do not hesitate to contact us 

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