The installation of closed-circuit television (CCTV) in schools may be normal practice in many countries, but for Cyprus, it is an unprecedented phenomenon. In some European countries and more broadly in the United States, the desire to keep children, teachers, and staff safe has led to a dramatic increase in the number of institutions installing security cameras as part of their security systems.
Camera surveillance in schools has recently sparked immense public interest in Cyprus. The Ministry of Education, Culture, Sports, and Youth of Cyprus, in collaboration with all relevant authorities (such as the Police, School Inspectorate, Commissioner for Personal Data Protection, etc.), has been systematically working over the past few months on the prevention and tackling of violence and delinquency in schools, an issue that has long troubled Cypriot society. Therefore, with the aim of preventing and addressing violence and delinquency in schools, which has seen an increase recently, the Ministry deemed that the installation of CCTV in school units "would alleviate" such incidents and could address the phenomenon.
The aforementioned issue was of utmost importance, as it could pose a high risk to the interests of citizens due to concerns regarding privacy violations and the processing of personal data, especially of minors, which, according to Regulation (EU) 2016/679, require enhanced protection, taking into account the principles governing data processing (Articles 5-11 of Regulation (EU) 2016/679).
The main concerns raised and discussed during the consultations between the Ministry and the competent Cypriot Data Protection Authority, which had to be weighed against the principle of proportionality regarding this issue, included privacy violations. Additionally, it was noted that the installation of cameras alone is not a sufficient measure to achieve the Ministry's goal of preventing law violations or crimes.
In light of the above, the Ministry, as the data controller, recognized the paramount risk that the installation of CCTV in school units could pose to the rights and freedoms of citizens on a broad scale, including minors. Therefore, it conducted an impact assessment, which was subject to consultation with the Authority.
It's worth noting that while the impact assessment conducted by the Ministry was not published, the Data Protection Authority, in view of the seriousness of the matter, proceeded to publish a summary of the consultation, obviously with the aim to promote trust as well as transparency. According to the relevant announcement by the Authority, video cameras will be placed at the main entrances and exits of school units, as well as their perimeters, and not within the school premises (e.g., indoor areas, classrooms, corridors, etc.), whereas relevant warning signs will also be placed for information and transparency reasons. Moreover, the recording range will be limited within the boundaries of the school units, and adjacent private or public areas will not be recorded. Additionally, as a measure to minimize the processing of personal data, the CCTV will be deactivated outside school hours, and the recorded material will be stored for a period of 72 hours with strictly limited access. However, the summary did not clarify to citizens whether audio recording will be permitted or not, an issue that is crucial since such action might excessively intrude on the privacy of the data subjects.
In light of the issues raised before the Authority and following the confirmation of adoption of its final comments and recommendations, it was decided that the impact assessment meets the requirements of Article 35 of Regulation (EU) 2016/679. Therefore, the installation of CCTV in school units was approved, and consequently, the Ministry, as the data controller, is now able to commence the relevant processing activities and actions that were the subject of the submitted impact assessment.
The CCTV operation will commence on a pilot basis in 10 school units, which have been identified based on specific criteria and historical data as high-risk for delinquency.
Article provided by INPLP member: Alexia Kountouri (Papadopoulos & Associates LLC, Cyprus)
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