Facial recognition CCTV excluded from new data protection law by definition of “personal data”
25 April 2023
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I have come to the conclusion that the new definition of personal data in the Data Protection and Digital Information No.2 Bill (“No.2 Bill”) only applies to facial recognition CCTV if the data subject is on a watch-list. If the individual is not on a watch-list, and the camera images are deleted immediately after checking the watch-list, then personal data are not processed and there are no data protection obligations (e.g. no transparency) It then follows that if the watch-list,
