Use of CCTV in Disciplinary Processes: High Court rules on “further processing” of CCTV footage in an employee disciplinary action

The use of CCTV footage in disciplinary investigations was recently considered by the High Court in Doolin v The Data Protection Commissioner.1 In a decision that will be of interest to HR and data protection professionals, Hyland J considered that CCTV footage can be used by employers for specified purposes including disciplinary procedures provided this purpose is made clear to employees.  The case highlights, however, that while the purposes specified by an employer have some flexibility in interpretation, they will not be broadly interpreted.

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