CJEU - C-212/13 - Ryneš

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CJEU - C‑212/13 František Ryneš
Cjeulogo.png
Court: CJEU
Jurisdiction: European Union
Relevant Law:
Article 11 Directive 95/46
Article 13(1) Directive 95/46
Article 18(1) Directive 95/46
Article 2 Directive 95/46
Article 3 Directive 95/46
Article 7 Directive 95/46
Recital 10 Directive 95/46
Recital 11 Directive 95/46
Recital 12 Directive 95/46
Recital 14 Directive 95/46
Recital 16 Directive 95/46
Paragraph 3(3) of Czech Law No 101/2000 Sb. on the Protection of Personal Data
Paragraph 44(2) of Czech Law No 101/2000 Sb. on the Protection of Personal Data
Paragraph 5(2)(e) of Czech Law No 101/2000 Sb. on the Protection of Personal Data
Decided: 11.12.2014
Parties: František Ryneš
Úřad pro ochranu osobních údajů,
Case Number/Name: C‑212/13 František Ryneš
European Case Law Identifier: ECLI:EU:C:2014:2428
Reference from: Nejvyšší správní soud (Supreme Administrative Court)
Language: 24 EU Languages
Original Source: Judgement
Initial Contributor: Elaine Thuo


On 11 December 2014, the Court decided the Rynes case. The decision concerns the interpretation of the processing of personal data using the operation of a camera system installed on a family home for the purpose of security.

English Summary

Facts

Mr. Rynes installed a camera system on his family home for the purpose of protection, health and life of his family. His family had, for several years been subjected to attacks by unknown people and it was difficult to identify them. The camera system recorded the entrance to his home, the public foot path, and the entrance to the house opposite his home. On the night of 6th to 7th October 2007, there was an attack on his home. The camera system made it possible to identify the two suspects involved. Mr. Rynes handed over to the police the recording to be relied on in the criminal proceedings. One of the suspects questioned the legality of the video recording and Mr Rynes was found to have infringed Law No. 101/2000 with respect to the protection of personal data. In particular, he was found to be a data controller who used the camera system to collect information without the consent of persons moving on the streets or opposite house. In addition, he had failed to inform them of the processing of personal data and lastly, as a Data Controller, he had not fulfilled the obligation to report the processing to the relevant office. Mr Rynas brought an action challenging this decision before the Prague City Court who dismissed the action. He appealed the decision to the Supreme Administrative Court who stayed the proceedings and referred the matter to the CJEU.

Dispute

The dispute in question is whether the operation of a camera system on a family home for the purposes of protection of the owners of the home, even though it monitors a public space, can be classified as the processing of personal data by a natural person as defined under Article 3(2) Directive 95/46.

Holding

The court assessed the question on processing for purely domestic purposes and noted that processing that involves a public space even though the installation is made on a private home does not fall under the exception under Article 3(2) Directive 95/46. For the exception to apply, the processing must be purely personal.

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