On January 29, 2020, the European Data Protection Board ("EDPB") released Guidelines 3/2019 on processing personal data through video devices ("Guidelines"). The Guidelines shed light on the EU General Data Protection Regulation ("GDPR") requirements applicable to this type of processing.

While some might debate whether a supreme being is watching us, there is little doubt that cameras and other devices are. Video surveillance systems processing pictorial and audiovisual information are increasingly used. The public and private sectors use these technologies for various purposes, including enhancing security, providing audience analysis, delivering personalized services and displaying advertising. The intrusion into individuals' lives is becoming more and more pervasive.

The Guidelines are the Ark of Covenant from which organizations processing personal data through video devices could seek the "Ten Commandments" for obeying GDPR requirements. (Other prescripts might be imposed by domestic laws, though.) This Legal Update discusses each of the 10.

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.