CNPD - DELIBERAÇÃO/2019/222

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CNPD - DELIBERAÇÃO/2019/222
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Authority: CNPD (Portugal)
Jurisdiction: Portugal
Relevant Law: Article 13(1) GDPR
Article 13(2) GDPR
Type: Investigation
Outcome: Violation Found
Decided: 25.03.2019
Published: 25.03.2019
Fine: 2000 EUR
Parties: n/a
National Case Number/Name: DELIBERAÇÃO/2019/222
European Case Law Identifier: Processo n.º 10770/2018
Appeal: Unknown
Original Language(s): Portuguese
Original Source: CNPD (in PT)
Initial Contributor: {{{Initial_Contributor}}}

Portuguese DPA rules that not posting signage about CCTV footage collection in covered areas represents a breach of the controller's information duties under article 13 GDPR

English Summary[edit | edit source]

Facts[edit | edit source]

The controller had installed in its facilities a video surveillance system with 9 cameras and 1 recorder. During an inspection to the facilities by the public police forces, officers found that no signage warning passers-by about the functioning of such a system was posted. The situation was reported to the Portuguese DPA.

Dispute[edit | edit source]

Is posting signage about CCTV footage collection mandatory under the GDPR? And should it contain all elements from article 13 GDPR?

Holding[edit | edit source]

The Portuguese DPA stresses that the controller should have known that it was obliged to post the aforementioned signage and that such signage should have contained all elements from article 13 GDPR. When deciding on the amount of the fine, the Portuguese DPA considered that the controller fully cooperated with the police forces' and the CNPD's investigations.

Comment[edit | edit source]

Further Resources[edit | edit source]

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English Machine Translation of the Decision[edit | edit source]

The decision below is a machine translation of the Portuguese original. Please refer to the Portuguese original for more details.