CCTV: German company sees the first big fine of 2021.

18th January 2021CCTV

With so many of us working from home at the moment, worrying about CCTV monitoring in the workplace is furthest from our minds.  But not for German company Notebooksbillger, who sell computers and laptops, who have just been fined €10.4million for using video surveillance to monitor its employees for more than 2 years without any legal basis.

The legislator criticised the company for not finding alternative ways to prevent criminal offences and said that CCTV was not justified, particularly as the company did not have ‘justified suspicion against specific persons’ which could have made the use of CCTV lawful, albeit for a short period of time.

Notebooksbillger were also criticised for monitoring customer seating areas and holding on to the recordings for 60 days – retaining images for this long can get you into difficulty – not least because it makes responding to subject access requests very difficult.

This is a substantial fine and whilst it has not yet been formally confirmed the company have already said that they intend to challenge it in court because they feel that it is disproportionate.

Even if the size of the fine does get reduced in court (and this may well be the case, as there is a precedent for this), the reputational damage done by this, particularly to a technology company, will be very difficult to recoup.

Protect yourself and your reputation: Things to consider in order to use CCTV and surveillance cameras compliantly:-

  1. You must always complete a Data Protection Impact Assessment (DPIA) if you are going to utilise CCTV or any form of recording devices.
  2. What is the problem you are trying to solve?  Could it be addressed another less privacy intrusive way?
  3. Is the use of a surveillance system a proportionate response to the problem?
  4. Establish the legal basis (under GDPR article 6) for the use of the CCTV monitoring
  5. Utilise CCTV best practice including:
  • Data minimisation
  • Purpose limitation
  • Accuracy
  • Retention
  • Confidentiality (keep monitored data secure)
  • A clear CCTV policy, well communicated.

For more information you can visit the Information Commissioner’s Website and also download their guide:

In the picture: A data protection code of practice for surveillance cameras and personal information. 

It is our view that surveillance is going to be a hot topic in the months to come because it was one of the key areas the EU are concerned about with regard to granting the UK an Adequacy decision.

If you are utilising CCTV or surveillance devices in your business and you are unsure whether you are using it lawfully, please do get in touch and speak to one of our specialists.

For additional insight and legal interpretation on this matter read the blog by legal compliance specialists Cordery Compliance.

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