The European Association of Co-operative Banks (EACB) welcomes the opportunity to provide the European Data Protection Board (EDPB) with its comments on the draft Guidelines on processing of personal data through video devices adopted in July this year.
The EACB is concerned that the draft Guidelines’ requirements are in conflict with the concept of proportionality as defined in the EU law, as they often exceed the scope of the articles set out in the GDPR and the measures proposed are not suitable to achieve a legitimate aim. The Guidelines practically ignore all safety-at-work and security aspects of video surveillance.
Furthermore, the draft Guidelines also expect the production and keeping of extensive documentation, including: detailed documentation on the video cameras in use, the monitoring purpose, the legal basis / legitimate interest etc.; transparency and information obligations with very extensive first-layer information; general video surveillance policies and procedures, etc.. We would like to note that such extensive documentation and information would not be strictly necessary/required under the GDPR.
To read in details the EACB’s specific comments, please download the PDF.