CIPM: Certified Information Privacy ManagerDemo

Identifiable CCTV footage is personal data, and using footage collected for facility security to routinely monitor staff performance or support discipline may violate purpose-limitation, lawfulness, transparency, and proportionality requirements. A regulatory investigation therefore requires advice from counsel experienced in privacy law and litigation to assess exposure, preserve relevant material, manage regulator communications, and determine an appropriate response. The Irish Data Protection Commission specifically notes that CCTV used for security and safety may not be repurposed for employee-performance monitoring when that further processing is incompatible with the original purpose.