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30/ Jun

Legal news

Personal data

Video surveillance CCIN authorises cameras to film the interior of lifts in public areas

Since 17 May 2023, the Commission de Contrôle des Informations Nominatives (CCIN) has authorised the use of cameras filming the interior of lifts in places open to the public, with the aim of improving security.

The CCIN thus indicated that:

"At its plenary meeting on 17 May 2023, the Commission reconsidered its position on cameras installed in lifts located in places open to the public (shops and museums, for example). Until now, the Commission had required these cameras to be oriented so as to film only the lift doors.

However, when examining a video surveillance system that a luxury shop wished to install, the Commission considered that cameras could even film the interior of the lifts serving the various floors of the establishment, as long as the objective was to reinforce the security of the premises and prevent the risk of theft and assault."

The Deliberation no. 2010-13 of 3 May 2010 concerning recommendations on video surveillance systems implemented by private individuals or legal entities remains nonetheless applicable.

The CCIN points out that, given the intrusive nature of video surveillance systems, they can only be used for the following purposes:

  • to ensure the safety of individuals
  • to ensure the safety of property
  • to control access
  • to provide evidence in the event of an offence.

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It is also worth remembering that the CCIN makes video surveillance in shops subject to the following rules in particular:

  • Private areas made available to customers (private lounges) must not be filmed unless they are used to show them valuables;
  • Unless there is a specific justification (e.g. checkouts), employees' workstations must not be filmed;
  • Given the number of cameras installed, the video surveillance system must not lead to permanent and inappropriate monitoring of the people concerned;
  • Once the lens has been moved, mobile cameras must not film employees' workstations, private areas made available to employees for relaxation or lunch breaks, private areas made available to customers (waiting rooms), or the public highway;
  • Postings must include at least one pictogram representing a camera and indicate the name of the department to which the right of access is exercised in the Principality;
  • The notice must ensure that the person concerned is provided with visible, legible and clear information and must be displayed at every entrance to the establishment;
  • The right of access may only be exercised on site;
  • The Monegasque Police may only have access to the information covered by the processing within the strict framework of their legally conferred duties.
  • The list of names of persons having access to the data processing must be kept up to date and must be provided to the Monegasque Police at the first request;
  • Unused ports must be deactivated and servers, peripherals, connection equipment (switches, routers, firewalls) as well as each user and administrator account must be individually protected by an identifier and a password deemed to be strong and regularly renewed.
  • The data controller must ensure that the angle of view of the cameras does not film the public domain, in particular pavements and accesses to buildings.

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