SECTORIAL  Unlawful processing of personal data in the context of disciplinary investigations by identifying the data subjects using surveillance cameras Cover Image
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SECTORIAL Prelucrarea nelegală a datelor cu caracter personal în cadrul efectuării cercetării disciplinare prin identificarea persoanelor vizate cu ajutorul camerelor de supraveghere
SECTORIAL Unlawful processing of personal data in the context of disciplinary investigations by identifying the data subjects using surveillance cameras

Author(s): Răzvan Viorescu
Subject(s): Law, Constitution, Jurisprudence, Civil Law
Published by: Universul Juridic
Keywords: disciplinary investigation; subordination of the parties; employer's prerogative to impose disciplinary sanctions; vi;, ECHR; Article 8;

Summary/Abstract: The European Police Union – EUROPOL has notified the National Supervisory Authority for Personal Data Processing, complaining of a violation of Regulation (EU) 2016/679 (GDPR), in conjunction with Article 5 of Law No. 190/2018, arguing that the use of images captured by the surveillance system for disciplinary purposes constitutes unlawful processing of personal data. Subsequently, after a six month investigation, in December 2025, the National Supervisory Authority for Personal Data Processing issued a warning to the Mehedinţi County Police Inspectorate, finding that it had violated personal data protection legislation at both European and national level. With regard to the penalty regime applicable to public authorities in Romania, we note that this is regulated by Law No. 190/2018, which provides that public authorities are first sanctioned with a warning, to which a remediation plan is attached (Article 13 of Law No. 190/2018).

  • Issue Year: 2025
  • Issue No: 01-02
  • Page Range: 75-92
  • Page Count: 18
  • Language: Romanian
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