Monitoring Premises Using a Video Camera System

Do you use a video camera system to monitor your premises?


If yes, this is considered to be processing of personal data of people present on your premises. Such personal data processing is subject to the European General Data Protection Regulation (GDPR), Slovak data protection legislation and the Guidelines on Processing of Personal Data Through Video Devices adopted by the European Data Protection Board (EDPB) in January 2020. In addition, video systems are frequently subject to inspection by the Office for Personal Data Protection of the Slovak Republic.


 

Video system operators must undertake the following legal requirements:
  • Define the purpose of personal data processing through the video system (e.g. protection of company’s property) and establish a legal basis for processing – otherwise it could be considered unlawful personal data processing
  • Position the video cameras so that only the premises which may be monitored are monitored, and only to an appropriate extent
  • Determine the storage period for video recordings
  • Set up processes to secure the rights of data subjects – e.g. the right of access, the right to object and the right to erasure
  • Introduce appropriate security measures to ensure the security of personal data
  • Prepare documentation in line with legislation – e.g. a record of processing activities, legitimate interests assessment, contract on personal data processing with each processor
  • Meet the obligation to inform persons who will be monitored by a warning notice in the form of a sticker or a plate (with a video camera icon) and information on personal data processing in accordance with Article 13 of the GDPR

If the operation of the video camera system includes monitoring of employees, you are also subject to obligations under the Labour Code, in particular compliance with legal limits related to employee monitoring, and negotiation and information obligations of the employer.

What are the consequences of violating the personal data protection regulations?


Offenses related to personal data protection are subject to sanctions of up to EUR 20 mil. or up to 4% of total annual turnover of the preceding financial year, whichever is higher. Since the effective date of the GDPR (25 May 2018), 51 of 98 inspections have been completed in Slovakia. More than a third of the completed inspections focused on inspecting personal data protection when video camera monitoring was in place.


 

We will be pleased to help you meet legal requirements:

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  • Are you planning to set up a video camera system? We will prepare the documentation and set up the required processes as regards personal data protection.
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  • Do you already operate a video-camera system, but are not sure whether you meet all the current requirements? We will assess the compliance of your situation (your processes and documentation) with the applicable requirements, identify shortcomings and advise on how to eliminate them. We can also help you implement our recommendations and provide advice on the operation of video camera system.
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  • Do you have any questions regarding the operation of a video camera system? We will give you advice to the extent you need.

Contact us

Nora Šajbidor

Nora Šajbidor

Manager, PwC Slovakia

Tel: +421 903 683 707

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