• Video surveillance is considered a particularly • Finally, employers must consider the principle of intrusive form of data processing, as it potentially data minimization by storing personal data for the allows for observance and analysis of a person’s minimum amount of time necessary and with a entire behavior. Therefore, the employer should specified retention period. In the case in question, carefully ensure to respect the principles of fairness, the DPA stated that 60 days was significantly longer transparency and proportionality. than necessary. ° When balancing the interests in question, the • For further reading on processing personal data employer must ensure that the data processing of employees, see A29WP Opinion 2/2017 on data is necessary and proportionate to the concerns processing at work or EDPB guidelines 3/2019 on raised. If a less intrusive method can achieve the processing of personal data by video devices. same goal, the less intrusive method must be used. Consider other methods of risk mitigation than video surveillance (e.g., random bag checks). Published: 08-01-2021, Journal number: n/a Tags: 01 Legal basis and principles of processing 43