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  5. The French Data Privacy Authority (CNIL) imposes a 100 000€ fine on a company who did not properly implement its video surveillance system
International

The French Data Privacy Authority (CNIL) imposes a 100 000€ fine on a company who did not properly implement its video surveillance system

Published on : 23/10/2025 23 October Oct 10 2025
Newsletter / Recent Case Law
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A company which had installed a hidden video surveillance system to detect workplace theft was fined 100 000€ namely because it had not been able to demonstrate that the system was temporary and proportionate.

Under French law, any system which monitors staff’s activity such as video surveillance requires respecting certain obligations namely consulting the Works Council and informing staff. In certain limited cases, it is possible to install such systems without informing staff. However, in this case the company needs to demonstrate why this was necessary and this can only be a temporary measure. Moreover, according to the General Data Protection Regulations (GDPR), this type of data collection needs to be properly documented.

In the present case, the company had installed hidden cameras in a stockroom which was discovered by staff who complained to the CNIL. The company could not demonstrate that such cameras were temporary in nature. The fact that they had not consulted their Data Privacy Officer, had not registered these cameras in their GDPR register, had not carried out a preliminary data privacy analysis and moreover had installed cameras which also recorded staff’s conversations contributed to the CNIL imposing a hefty fine.

Ensure that any systems which monitor staff’s activities are compliant with French labor law and data privacy rules. 
 
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