EDPB Guidelines 3/2019 on Processing of Personal Data through Video Devices
Section 3: Lawfulness of processing – EDPB Guidelines 3/2019 on Processing of Personal Data through Video Devices

EDPB Guidelines 3/2019 on Processing of Personal Data through Video Devices 3.1.3.2: 3.1.3.2 Reasonable expectations: no cameras where people expect privacy, including most workplaces, washrooms and rest areas

Reasonable expectations are judged objectively, by whether a neutral third party would expect monitoring in that situation. An employee at the workplace in most cases does not expect to be monitored by the employer; monitoring is not expected in private gardens, living areas, examination and treatment rooms, and it is an intense intrusion in sanitary or sauna facilities, where no surveillance should take place. People can also expect freedom from monitoring in publicly accessible areas used for rest, recovery and leisure or where they sit and talk (restaurant tables, parks, cinemas, fitness facilities). A sign announcing cameras does not change what people can objectively expect.

Maintained by Gerard Blokdyk

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