If your organisation plans to introduce body-worn cameras, there is one crucial step to take before they are activated: conducting a Data Protection Impact Assessment (DPIA).
Across the European Union (EU), European Economic Area (EEA), and other countries with GDPR-aligned laws, body cameras offer clear benefits, including improved safety, transparency, and evidence gathering. However, they also come with serious responsibilities under data protection law. A DPIA isn’t just good practice—it is a legal requirement under the GDPR when the processing of personal data is likely to result in a high risk to individuals’ rights and freedoms.
What You Need to Know Before Using Bodycams
A DPIA is a structured process that helps organisations identify, assess, and reduce privacy risks when handling personal data. It is essential when introducing new technologies, such as body-worn cameras.
It helps answer key questions:
- What data are we collecting?
- Why is it necessary?
- Who could be affected?
- What could go wrong?
- How will we safeguard people’s rights?
Starting with a DPIA ensures that your bodycam programme is lawful, ethical, and accountable.
Why Data Protection Matters in These Projects
Body cameras capture images, audio, GPS data, and interactions between people. Under the General Data Protection Regulation (GDPR), this qualifies as high-risk data processing. According to Article 35 of the GDPR, a Data Protection Impact Assessment (DPIA) must be conducted before implementing any technology that could significantly affect individuals’ rights and freedoms.
An essential yet often overlooked aspect of this assessment is understanding where data is stored and the locations of any backups. Headlines increasingly highlight organisations’ efforts to reduce reliance on non-EU cloud services due to privacy concerns. A DPIA helps identify whether data is stored in jurisdictions with differing legal protections, such as the US.
When a DPIA Is Required
A DPIA is mandatory when your data processing involves:
- Systematic monitoring in public or private spaces
- Combined audio and video recording
- Special category data (e.g. racial or ethnic origin, health status, political opinions)
- Location tracking via GPS
- Large-scale or high-impact usage, such as by public authorities
Examples of High-Risk Scenarios
- Law enforcement at public events, capturing political views or sensitive interactions
- Healthcare or mental health settings where private conversations are recorded
- Public transport environments with high volumes of passenger data
Key Elements of a Strong DPIA
A well-conducted DPIA should provide a clear picture of the planned deployment and its impact on data protection. It typically includes:
- Project summary: what the deployment involves and its objectives
- Purpose and legal basis: define the purpose first, then reference the applicable GDPR article
- Data types: video, audio, GPS, and metadata
- Affected individuals: including staff, citizens, and vulnerable groups
- Storage and access: where the data and backups are stored, and who can access them
- Risk analysis: assess how individuals’ rights and freedoms might be impacted
A thorough risk analysis should include, among others, the following potential risks for data subjects:
- Privacy Breaches – Unauthorised access or covert monitoring
- Security Incidents – Data leaks or hacking of bodycams/servers
- Misuse of Data – Use for unintended purposes like surveillance outside of working hours
- Misidentification – Mistakes due to facial recognition or misinterpreted footage
- Psychological Impact – Increased stress or distrust among staff and the public
- Legal Consequences – Footage misused in legal proceedings, leading to unjust outcomes
To mitigate these risks, a DPIA should also define and document:
- Controls: such as encryption, access restrictions, audit logs, redaction, clear data retention policies
- Consultation: with the DPO and relevant stakeholders to validate the risk management approach
These steps ensure that the DPIA is not only a legal requirement but a practical guide to responsible technology use.
Who Should Be Involved
While the data controller remains legally responsible, a cross-functional team usually contributes:
- Data Protection Officer (DPO)
- Legal/Compliance team
- IT and cybersecurity experts (CISO)
This ensures the DPIA is complete, legally sound, and practically implementable.
What Authorities Expect
Each EU country has its own Data Protection Authority (DPA), and they expect DPIAs to be clear, thorough, and adequately documented. A DPIA can be requested during inspections, complaints, or investigations into data breaches.
How ZEPCAM Supports Privacy-First Bodycam Projects
Based in the Netherlands, ZEPCAM is a pioneer in the field of body-worn video solutions, with over 15 years of experience supporting frontline professionals. Today, hundreds of European public and private organisations rely on ZEPCAM for secure, scalable, and GDPR-compliant bodycam systems.
We understand that data protection and operational flexibility are critical in every deployment.
In line with our commitment to responsible data management, ZEPCAM has conducted a comprehensive Data Protection Impact Assessment (DPIA) for its services, following the NOREA framework. This assessment, which is available upon request, identifies the key privacy risks within the organisation. It confirms that these risks have been adequately addressed and concludes that our data processing activities are lawful and in compliance with GDPR standards. Additionally, we have carefully considered the rights and freedoms of data subjects.
To accommodate a wide range of operational and regulatory needs, ZEPCAM offers several secure deployment options:
- Cloud hosting within the European Economic Area (EEA), including Microsoft Azure (Netherlands or other EEA locations) and SmartDC in Rotterdam
- On-premise hosting, fully controlled and managed by the organisation itself
- Hybrid configurations, combining local storage with secure, encrypted cloud offload
All data is encrypted using AES-256, both in transit and at rest. ZEPCAM Manager provides secure, centralised control of user access, recordings, live streams, retention schedules, audit logs, and redaction tools. With configurable access rights, organisations maintain full compliance, transparency, and accountability across all levels.
From law enforcement to healthcare, municipalities to public transport and private security, ZEPCAM empowers teams to operate safely, effectively and fully aligned with European privacy regulations.
For more information about implementing secure, GDPR-compliant bodycam systems or to discuss your organisation’s specific needs, feel free to contact our team.
