Position Paper Bitkom views on the EDPB Guidelines 3/2019 on processing of personal data through video devices
Bitkom welcomes the opportunity to comment on the European Data Protection Board’s (EDPB) draft Guidelines on processing of personal data through video devices. We believe that more cooperation and exchange between data protection authorities and practitioners is needed to translate the legal text of the GDPR into practice and reduce legal uncertainty. Especially in the field of video surveillance (and other image-related data processing) there is still a lot of uncertainty. In our opinion, the Guidelines should aim at providing practical Guidance and to strike a balance between the interests concerned. That includes, on the one hand, not overly restricting the use of data processing through video devices but on the other hand clarifying which uses are not considered appropriate. Both factors are important to build trust in digital technologies, further innovation and protect the data subject´s rights.
Our full Position Paper with detailed analyses of the EDPB´s Draft Guidelines is available for download here.