GDPR-compliant body cam use
Body cameras have a de-escalating effect, protect employees and provide recordings that can be used in court in serious cases. This requires GDPR-compliant use.
Body-Cam Comply with data protection regulations and reap the benefits
With our support, easily overcome data protection hurdles and experience the benefits of using body cameras, such as:
De-escalation
Body cameras can command more respect simply by their presence, thereby preventing dangerous situations before they arise.
Mirror function
A front display allows aggressors to reflect on their behaviour and, if necessary, deter them from committing a crime.
Evidence preservation
Admissible recordings capture the correct behaviour of your staff and possible offences by aggressors.
GDPR-compliant use of body cameras is essential in order to be able to use recordings in court. To make this easy to implement, here is an overview of the points that should be taken into account.
Legal basis for the use of body cameras
The use of body cameras for video surveillance requires a legal basis in accordance with Art. 6 GDPR. In most cases, data processing is based on Art. 6(1)(f) GDPR (the legitimate interest of the controller). A balance must be struck between the interests of the operator (e.g. protecting employees from assaults) and the rights of the persons filmed.
Interests of the operators
e.g. Protection of employees against assaults
Rights of the persons filmed
Protection of personal data
The Conference of Independent Data Protection Supervisory Authorities of the Federal Government and the Länder (DSK) emphasised that the use of body cameras must therefore always be event-related and purpose-specific.
Important: If image and sound are recorded, this increases the intrusion into the rights of the persons concerned. The assessment must be documented and reviewed regularly.
Legal basis in police lawsInformation obligations under Art. 13 GDPR – The ECJ ruling 2025
In its ruling of 18 December 2025 (C-422/24), the European Court of Justice clarified that if personal data is collected using body cameras, Article 13 of the GDPR applies. Data subjects must be informed immediately at the time of data collection and not only afterwards.
The case: AB Storstockholms Lokaltrafik
The Swedish transport company has been equipping ticket inspectors with body cameras since 2018. According to the Swedish Data Protection Authority, their use was not in compliance with data protection regulations. For this reason, it imposed a fine for failing to provide passengers with adequate information.
Fine
ca. 0 €
The tiered information model:
The ECJ confirms that the information requirements can be fulfilled within the framework of a step-by-step procedure with the help of the EDPB Guidelines 3/2019 on video surveillance:
First level: The most important information can be displayed on a notice sign.
Second level: The additional mandatory information can be provided in an easily accessible location.
Please note: The EDPB guidelines specify in detail which information is to be displayed at which level. However, the ruling makes it clear that the application of Article 14 GDPR (subsequent information) is excluded for body cameras, as this could otherwise lead to "covert surveillance practices".
Necessary data protection measures
Quick checklist:
- Create deployment concept
- Define the purpose of processing
- Establish a processing directory
- Prepare order processing agreement
- Comply with transparency requirements (duty to provide information)
- Adapt works agreement
- Perform a data protection impact assessment
- Correct configuration of the body camera
How is a GDPR-compliant deployment concept created?
The use of body cameras is only permitted if it is related to clearly defined purposes. To ensure that they are used for their intended purpose, a usage concept must be created. This should be part of a service or operating agreement and include the following points:
Define purpose
What is the intended outcome of the deployment? (e.g. protection of own personnel from assaults)
Set location
Where are recordings permitted?
Ensure transparency
What should be done just before recording?
Documentation
How is a successful recording documented?
Evaluation
How and how often is the deployment evaluated?
Set TOM
What technical and organisational measures (TOM) are taken to protect personal data?
Note: Details on all points listed can be found in our guide.
Body-Cam Practical Guide
All notes & tips for introduction
To obtain a detailed overview of all measures for GDPR-compliant use of body cameras, you can request our guide to introducing body cameras. This also includes what needs to be done from an operational perspective to ensure that your body camera project is implemented with ease. In addition to the guide, our expert team is also on hand to assist you. Everything you need to know:
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