An image is personal data
When your cameras record the faces of passers-by, staff and visitors, you are processing personal data. This does not mean surveillance is forbidden — surveillance for a legitimate purpose (protecting property and safety) is accepted — but it does mean you carry responsibility for how it is collected, stored and accessed.
Legitimate purpose and notice
Two basic principles:
- A legitimate, specific purpose: you record to protect your site and its safety, not to watch people without justification.
- Notice: a clear sign stating the place is under surveillance. This respects people’s right to know they are being recorded, and it is accepted practice wherever surveillance operates.
Where recording is not permitted
There are limits that are not crossed:
- Private places: toilets, changing rooms, and anywhere people expect complete privacy.
- A neighbour’s privacy: your door camera must be aimed at your property and your entrance, not into a neighbour’s house or windows. Aiming at the street to cover your own entrance is normally accepted; deliberately watching a neighbour’s privacy is not.
- Staff private areas: handled with care and with notice.
Retention and who reaches the recordings
Keeping people’s data indefinitely without justification conflicts with the principle of data minimisation. Keep it for the period the purpose requires (and that your authority requires), then let it be overwritten. And define who may view and export recordings — not a monitor on display to every passer-by, and not recordings within reach of any employee.
Audio is more sensitive
Recording audio alongside video raises the sensitivity considerably, because recording conversations touches privacy more deeply than an image alone. Audio is not enabled by default; where it serves a specific purpose it must be justified, clear and signposted.
How to design a system that respects privacy
- Aim each camera at a specific purpose within the bounds of your property.
- Put notice signs at the entrances.
- Set a reasonable retention period and size the disk to it.
- Restrict access to the recordings to named people with passwords.
- Avoid audio unless there is a clear justification.
A system that respects privacy is not weaker; it is legally sounder — it protects you as much as it protects the people you record.
