When placing cameras for observation without recording, is personal data being processed?
ANSWER
According to the guidelines of the President of PUODO published at https://uodo.gov.pl/pl/138/354 (p. 23, point 11), where monitoring serves only to view a given place and the image is not stored anywhere, personal data processing cannot be said to occur. Under the definition of processing of personal data in Article 4(2) GDPR, processing includes, among other things, collecting or viewing personal data, which cannot take place where no recording is stored.


