Storstockholms Lokaltrafik: Insufficient legal basis for data processing

The Swedish DPA has fined Storstockholms Lokaltrafik (Stockholm Local Transport Company) EUR 1,600,000. The controller had equipped ticket inspectors with body-worn cameras, which were designed to prevent threatening situations, document incidents, and ensure that the right person was fined for traveling on Stockholm's public transportation without a valid ticket. Ticket inspectors were required to keep the camera on for their entire shift and were therefore able to film all passengers who passed the inspector. Since several hundred thousand people use public transportation in Stockholm every day, a large number of people were thus at risk of being monitored by video and audio recordings. The DPA believes that body-worn camera technology could be used to prevent and document threatening situations, but that the pre-recording time should be reduced to a maximum of 15 seconds, as a longer pre-recording time is not necessary to achieve the above-mentioned purposes.

Furthermore the DPA found that audio recordings did not contribute to the identification of persons without a valid ticket. The DPA therefore considered the audio recordings to be a violation of the principles of legality and transparency as well as data minimization. The DPA also criticized the controller for not providing sufficient information about the camera surveillance, including the fact that not only images but also sounds were recorded. GDPR Articles: Art. 5 (1) a), c) GDPR, Art. 6 (1) f) GDPR, Art. 13 GDPR Industry: Transportation and Energy