GDPR art 13 or art 14 on Body Camera’s surveillance (ECJ) ?

Core Question:
When ticket inspectors use body cameras to record passengers (images + sound), does the duty to inform under the GDPR fall under Article 13 (direct collection) or Article 14 (indirect collection)?

Key Findings:

  1. Direct Collection = Article 13
    • Data from a body camera is collected directly from the data subject by observation, without intermediaries.
    • Article 13 applies even if the subject does not actively provide data or is unaware before recording.
    • Awareness of surveillance should result from compliance with Article 13, not be a precondition for it.
  2. Why Not Article 14?
    • Article 14 covers indirect collection (data from third parties or other sources).
    • Using Article 14 here would weaken transparency, delay informing subjects, and risk hidden surveillance.
  3. Timing of Information:
    • Article 13 requires info “at the time when personal data are obtained” (immediately).
    • Article 14 allows delays (up to 1 month), but these are irrelevant for direct body cam collection.
  4. Practical Application – Layered Approach:
    • Controllers must take appropriate measures (Art. 12 GDPR) to inform clearly and accessibly.
    • For body cams, warning signs act as the first layer; more detailed info (e.g., via QR codes, websites, printed leaflets) forms the second layer.
    • This method, used in fixed CCTV, is equally applicable to mobile body cameras.
  5. No Exception for Disproportionate Effort:
    • The Art. 14(5)(b) “disproportionate effort” exemption is irrelevant because the collection is direct.
  6. Risk & Transparency Principle:
    • Body cam recording is as intrusive as fixed CCTV and carries high privacy risks.
    • Transparency is essential so that people can adapt their behaviour or avoid monitored areas.

Conclusion of the Advocate General:

For personal data collected by body cameras worn by ticket inspectors in public transport, Article 13 GDPR applies and Article 14 does not.

Source: EUR-Lex – 62024CC0422 – EN – EUR-Lex