With two distinct opinions, the Privacy Guarantor gave the Ministry of Interior the green light • Department of Public Security and the General Command of the Carabinieri Arm to the use of body cams to document critical situations of public order at events or events The two Police Forces will have to accept some indications of the Authority regarding the implementation of security measures and the tracking of access to data in order to make the processing fully compliant with the law on the protection of personal data processed for the prevention and detection of crimes (Legislative Decree no.
The Authority has asked the Ministry in particular to specify that the system it intends to use does not allow the unique identification or facial recognition of the person, as already specified in the documentation transmitted by the weapon. The two systems, subject to the Guarantor independently, present remarkable similarities, not only with regard to the objectives pursued, but also from the structural point of view, with the exception of the differences attributable to the specific organizational structures of the two Police Forces. The wearable cameras used by the staff of the mobile departments in charge can only be activated in the presence of real and concrete situations of danger of disturbance of public order or of crime. Continuous recording of images and even non-critical episodes are not allowed. The data collected are about audio, video and photo of the people filmed, date, time of recording and Gps coordinates, which once downloaded from the cameras are available, with different levels of accessibility and security, for subsequent verification activities.
The two opinions given by the Guarantor on the two impact assessments submitted by the Ministry and the Arma take into account the in-depth analysis carried out by the Authority’s offices.
Unlike what the Ministry and the Arma, who had submitted the Dpia did not consider necessary the prior consultation of the Authority, the Privacy Guarantor has stated that according to the Decree such consultation is due, as the risks for the persons filmed can also be And the use of body cams during public events makes it extremely likely to process data revealing political, trade union, religious or sexual orientation of participants.
The Privacy Supervisor considered among other things the six-month period of data retention reasonable and respected the principle of privacy by default, being provided for their automatic cancellation after that deadline.
The Authority has finally recommended to the Administrations to evaluate the possibility of sharing the original documents with all the authorized subjects remotely, without the use of the production of copies.