Case Studies CCTV

 

CCTV in Restrooms

Each year the DPC receives numerous queries and complaints from various individuals complaining specifically about the use of CCTVs in restroom areas by various organisations such as public houses, nightclubs, restaurants and transport depots. More particularly, the complaints allege that the cameras are pointing over specific areas in restrooms where there is an increased expectation of privacy, such as over cubicles or urinals.

While, the DPC has engaged with organisations on a one-to-one basis, the issue of the lawfulness of the processing of personal data by way of CCTVs in restrooms needs to be considered more generally. Consequently, the DPC has examined these issues further and updated its Guidance on CCTVs for Data Controllers by including a specific section on ‘The use of CCTV in areas of an increased expectation of privacy.

Key Takeaway

  • Organisations should avoid using CCTV where a reasonably high expectation of privacy exists (for example, over cubicles). The threshold for the use of CCTV in restrooms more generally, remains very high, and requires data controllers to identify and examine all the legitimate issues arising and to assess and implement appropriate measures which adequately protect the interests of individuals using those facilities which must be evaluated prior to the deployment of any system.
  • The DPC strongly recommends that all data controllers familiarise themselves with this updated guidance.