個人資料保護辦公室

Gabinete para a Protecção de Dados Pessoais

Office for Personal Data Protection

Enquiry Case Notes
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No: 0717/C/2011

Title: Installing driving video recorder

Content:

    Resident X claimed that some people installed car driving recorders on their vehicles, in order to capture driving records at the rear and from the front and both sides of the car. In the event of incident or disputes, the video record could be replayed or submitted to the public departments.
  X asked whether installing the said recorders will violate the Personal Data Protection Act.

Result:

    In the absence of detailed case information, GPDP could only provide the following opinions based on the general personal data processing:
  Car driving recorder is installed at the front, the rear or the two sides of a car. Therefore, if the road images captured by its camera include information of any identified or identifiable natural persons, this is regarded as personal data under Article 4(1)(1) of the Personal Data Protection Act (Law 8/2005). Normally, according to Article 3(1) of the same Law, the data processing thereof is regulated by the same Law.
  However, according to Article 3(2) of the said Law, if the installation of car driving recorders is for personal or household activities, and the captured images are not used for system communications or dissemination (such as uploading the images to the Internet), to which the said Law does not apply.
  If anyone found anyone’s use or installation of a car driving recorder violated the Personal Data Protection Act, he could file a complaint or report with the GPDP.

Reference:
Please refer to "Personal Data Protection Act", articles 3,4 .

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