The eighteen findings
In a fixed order, each a question for your privacy lead or your lawyer with the clause behind it. Magenta marks a question on the schedule; nothing else on the sheet is coloured.
- 1 Face matching or face recognition: biometric identificationWhich condition or written release covers each person this camera matches, and where is it recorded?
- 2 Behaviour or emotion alerts over an area where staff work, at an EU siteIf this alert infers emotion in a workplace it may be one of the practices Art. 5 does not allow: does the medical or safety exception apply? If it detects movement or objects only, it does not infer emotion. Which is it?
- 3 Demographic estimation at an EU siteWhich characteristics does this feature estimate, and does any of them fall within the categories Art. 9 lists?
- 4 Public area monitored with no assessment recordedIs this monitoring of a publicly accessible area on a large scale, and if so, where is the assessment?
- 5 No retention period set, or retention above the maximum you setWhat purpose sets this period, and where is it written down?
- 6 No signage or notice recordedWhat notice do people get before they enter this camera's view, and what does it say?
- 7 Footage stored outside the site's region: who can access it there?Who can access or use the footage where it is stored, and which transfer mechanism covers it: an adequacy decision or regulations, standard clauses, or another safeguard?
- 8 A third party can view or manage the footage, and no agreement is recordedWhat is this party's role (processor, joint controller, independent controller or recipient), and which agreement governs it?
- 9 Licence plate reading with no lawful basis recordedWhich basis covers reading plates here, and is it recorded?
- 10 Audio recordedIs recording sound needed for this camera's purpose, and who has consented to it?
- 11 Camera covering a staff-only private areaWhy does a camera cover this area, and can it be moved or switched off?
- 12 High-risk AI use in an EU workplaceIf this system is high-risk under Art. 6: who are the named people overseeing it, are its logs kept at least six months, and were workers and their representatives informed?
- 13 No owner, or no list of who can viewWho owns this camera and its footage, and who may view it?
- 14 Disclosures to police or insurers not loggedWhere is each disclosure recorded: what was handed over, to whom, when and on what request?
- 15 Covert cameraUnder what authority does this camera run covertly, who signed it off, and for how long?
- 16 Children in view of face matching or demographic estimationWhich Art. 9 condition covers the children this camera reads, and does the assessment deal with them?
- 17 Workplace surveillance law named for this siteWhich of the points the act named here asks about can you show for this camera?
- 18 Employee records exemption: does it reach this footage?Does this footage directly relate to the employment relationship, and does it also capture customers or visitors, who the exemption does not cover?