A specific preventive purpose
Define the problem to be addressed: remotely observing a dangerous operation, analysing an incident or detecting a particular condition. “Improving safety” is too broad if it does not explain what is captured and how it will be used.
The AEPD notes that images of identified or identifiable people are personal data, even if they are only viewed. A preventive purpose does not make every form of processing appropriate. Document its legal basis and avoid reusing images for incompatible purposes without the corresponding analysis.
Necessity and proportionality
Check whether a less intrusive alternative can address the problem: modifying the process, installing a safeguard or using information that does not identify people. A camera that shows a hazard does not eliminate it.
Limit the field of view, operating times, required resolution and retention to the justified purpose. Avoid capturing areas or activities unrelated to the objective. The AEPD links employer monitoring with proportionality and respect for dignity; technical convenience or low cost is not enough.
Information and workplace limits
In Spain, Article 89 of Organic Law 3/2018 requires prior, explicit, clear and concise information to workers and, where appropriate, their representatives about these monitoring measures. It prohibits recording or video surveillance systems in places intended for rest or recreation, such as changing rooms, toilets and dining areas.
Sound recording is subject to particularly restrictive conditions. A sign does not justify every subsequent use or by itself remedy a disproportionate system. Also review applicable employment legislation and agreements.
Access, retention and providers
Determine who may view images and for what reason. Separate technical administration from authorised use, log access where appropriate and protect accounts, connections and exports. Avoid distributing recordings through informal channels.
Set retention and deletion periods according to the purpose and applicable rules, including arrangements for images needed to clarify an incident. If a provider is involved, define responsibilities and service conditions. Also check where data is stored and which third parties can access it.
Image analytics and preventive use
If automated analytics are added, review accuracy, errors and consequences. Detecting an image is not the same as understanding the whole work situation. Alerts require clear procedures and a response that does not create new risks.
Consider whether processing requires a data protection impact assessment and which additional safeguards are needed. Do not infer emotions, blame or professional ability from an isolated sequence. To learn from an incident, combine images with technical information, context and participation by people who understand the task.
Hypothetical example: observing a transfer point
A company considers a camera to check blockages in a hazardous area without approaching it. It first reviews safeguards and limits the field of view to the equipment, avoiding neighbouring workstations.
It documents the purpose, access arrangements and information for those affected. If observation without recording meets the need, it considers that option instead of retaining continuous video. The decision is based on reducing exposure through proportionate capture, not permanently supervising the workforce.
