Guidance on Body Worn Cameras or Action Cameras

10th January 2020

The use of body worn cameras and similar devices has been growing in both scale and variety over the last number of years. They have numerous potential applications including recreation, security, and journalism, to name a few. Wearable technologies such as body worn cameras pose a particular challenge from a data protection perspective due to their mobile nature. Unlike CCTV systems, which can be carefully positioned to minimise the risk of inadvertent data collection, a body worn camera can effectively turn the wearer into a mobile surveillance system that is likely to capture the personal data of passers-by. When this type of technology is combined with microphones and/or facial recognition technology the data protection concerns increase.

This guidance is intended to assist the users of these recording devices in determining whether they are a ‘controller’ with obligations under data protection law, or whether their actions fall within the personal or household exemption, as well as what those obligations are and what steps users can take to ensure that they use these technologies in compliance with data protection law. This guidance also briefly discusses the use of these technologies for law enforcement purposes, although this is not the focus of this guidance note.

Body Worn Cameras or Action Cameras: Full Guidance Note