gdpr european-union recording poland
Is the Vilnius-Lublin portal a violation of GDPR?
<p>Don’t get me wrong, I love <a href="https://m.youtube.com/watch?time_continue=5&amp;v=TRvbxiCj79E&amp;feature=emb_logo" rel="nofollow noreferrer">it</a>!</p>
<p>But is it GDPR compliant given that people walk up to a camera that will broadcast their image outside of their country?</p>
<p>See also <a href="https://www.domusweb.it/en/sustainable-cities/gallery/2021/06/02/vilnius-and-lublin-are-now-connected-by-a-portal.html" rel="nofollow noreferrer">this news story</a> and <a href="https://www.boredpanda.com/virtual-door-lublin-vilnius-portal/?utm_source=google&amp;utm_medium=organic&amp;utm_campaign=organic" rel="nofollow noreferrer">this one</a></p>

<p>This is most likely OK. Yes, this installation involves the processing of personal data by capturing video feeds. However, this is likely covered by a legitimate interest in doing so. And a real-time video feed is less sensitive than the recording of the installation (such as the video you linked) since the feed is only visible to a small number of people who are in a particular public location. Since the feed is bi-directional, data subjects have a reasonable expectation of being seen, thus supporting a legitimate interest argument. The most difficult part of this installation would be adequate notice per Art 13 GDPR. For more guidance on usage on video cameras, consider <a href="https://edpb.europa.eu/our-work-tools/our-documents/guidelines/guidelines-32019-processing-personal-data-through-video_en" rel="nofollow noreferrer">EDPB guidelines 3/2019</a>, but they are mostly focused on video <em>surveillance</em>.</p>
<p>That the video feed is transferred to a different country does not matter, since both countries are in the EU. So no international transfer in the sense of Art 44 GDPR has taken place.</p>
