Case Studies CCTV

 

Failure to respond to a request for CCTV footage

The DPC received a complaint from an individual who had made an access request to a transport company. They sought a copy of CCTV footage of an accident they were involved in with one of the transports company’s buses. The individual did not receive a response to this request.

The DPC contacted the Data Protection Officer (DPO) for the transport company and informed them of the complaint.

The DPC reminded the transport company of their GDPR obligations, drawing their attention to Article 12(3) of the GDPR, which states that organisations have an obligation to provide a response to an individual’s subject access request within the statutory timeframe. As part of the engagement, the DPC stipulated a timeline for the transport company to respond to the individual and provide them with a copy of the CCTV footage. The transport company complied with the DPC’s direction and the individual confirmed they received the requested personal data.

Key Takeaway

  • Organisations should be aware that footage or images containing identifiable individuals captured by CCTV systems are personal data for the purposes of data protection law. 
  • Organisations are required to implement appropriate organisational measures in place to ensure that they are in a position to respond to any rights requests within the stipulated timeframes under the GDPR.
  • More information on this subject matter can be found at: Guidance on the use of CCTV