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Legal regulation of the use of dashboard

cameras: Aspects of privacy protection

Darius Štitilis, Marius Laurinaitis *

Mykolas Romeris University, Vilnius, Lithuania

A B S T R A C T

Keywords: This study aims to analyse and compare the legal regulations of selected countries related
Use of dashboard cameras to the use of dashboard cameras (dashcams) in vehicles and to publish the corresponding
(dashcams) in vehicles recordings of dashboard cameras in the context of privacy protection. Researchers used em-
Publication of recordings pirical analysis of legal documents and case law, as well as the analysis of the decisions
and opinions of the institutions in charge of data protection in selected countries to iden-
tify the legal regulation of dashcam use. The study selected countries in Europe that first
banned the use of dashcams, or that have enacted specific prohibitions or court decisions,
as well as those that do not prohibit their use and where the dashcams are in widespread
use. The article presents the authors’ position on the legal regulation and assessment of
dashcam use, i.e. that, according to the authors, dashcam use and/or publication of their
recordings should not be forbidden in the EU. The results of this research may be applied
to the regulation of corresponding relations as well as for assessment of situations con-
nected with the use of dashcams and/or publication of recordings made with dashcams
and related violations of the right to privacy and when interpreting various situations on
the use of dashcams and/or publications of their recordings.
© 2016 Darius Štitilis & Marius Laurinaitis. Published by Elsevier Ltd. All rights reserved.

prepared and is being discussed at the moment. When as-

1. Introduction
The development of information technologies and the trans-
fer of information into cyberspace increase the quality of
information processes and activities and ensure better com-
petitiveness and efficiency. But sometimes this creates negative
outcomes or controversial situations. The use of dashcams in
vehicles and the publication of dashcam recordings may be
mentioned as one of such areas. The publications of the re-
cordings raise questions and discussions in the process of
privacy protection.
Certain general privacy protection norms and principles are
applied in the EU. EU reform of data protection1 has been
sessing the application of these norms and principles to
situations when dashcams are used and when the material re-
corded with the help of this equipment is publicly published
in social networks or other public platforms (e.g. Youtube), ques-
tions arise about if people’s right to privacy is ensured in all
cases and what the limits of privacy are.
Most often in practice, data collected with the help of
dashcams are published after a certain incident or violation.
However, there are several questions that arise from this prac-
tice. Does a certain violation outweigh a person’s right to
privacy? Another question is how to assess the publication of
images of accidentally filmed people? Is publication on the
whole possible in certain cases? If the answer to these

* Corresponding author. Mykolas Romeris University, Ateities str. 20, Vilnius, LT-08303, Lithuania. Tel.: +370 61257973.
E-mail address: laurinaitis@mruni.eu (M. Laurinaitis).
http://dx.doi.org/10.1016/j.clsr.2016.01.012
0267-3649/© 2016 Darius Štitilis & Marius Laurinaitis. Published by Elsevier Ltd. All rights reserved.
1
Commission, ‘Proposes a comprehensive reform of the data protection rules’ (2012) <http://ec.europa.eu/justice/newsroom/
data-protection/news/120125_en.htm> accessed 10 February 2015.
 computer law & security review 32 (2016) 316–326
questions is yes, what should be the length of the published
recording (e.g. can a recording taking place before the inci-
dent and after the incident of any scope be published)?
Therefore, the situation needs to be analysed in the selected
countries by applying the principles of privacy protection and
IT law and corresponding case law, and by defining the guide-
lines for the legal regulation of the analysed situations.
This topic is important because citizens increasingly value
their privacy in several different areas, including the record-
ing of their activities.2
Currently legal regulation in the use of dashcams is devel-
oping in several directions:
• Some countries have special legal norms that forbid the use
of dashcams;
• Other countries attempt to regulate the use of dashcams
with special legal norms;
• Still, other countries attempt not to interfere in the use of
dashcams with legal tools leaving the freedom to the general
legal norms in force to solve the arising situations in the
context of privacy protection.
The authors intend to reveal the most suitable approach
through this research.
2. Historical background, possibilities and
tendencies of the use of dashcams
According to most sources, the beginning of dashcams can be
traced to the state of Texas in the United States in the 1980s.3
Texas installed video cameras in police cars and image and
sound were recorded onto VHS-type cassettes. Such video re-
cordings increased the safety of officers working in remote areas.
The first attempts to install video recording equipment in US
police cars were expensive and inconvenient. In the early 1990s,
the use of dashcams in police cars became an occurrence. The
necessity to control the behaviour of police officers and the
prevention of officer misuse could be named as the main reasons
for the use of dashcams. Based on dashcam recordings, it became
easier for police institutions to represent officers charged with
inappropriate behaviour while on duty.
As the technology became cheaper, dashcams became ac-
cessible also to ordinary consumers and the number of vehicles
with dashcams increased rapidly. In no other country dashcams
were as popular as in Russia.4 In the late 2000s, active scams
2
Special Eurobarometer 431, ‘Data Protection’ (June 2015)
<http://ec.europa.eu/public_opinion/archives/ebs/ebs_431_en.pdf>
accessed 26 February 2015.
3
Earnest Pettie, ‘A Brief History of Dash Cam Insanity’ (18 March
2013) <http://www.break.com/article/a-brief-history-of-the
-dash-cam-2425146> accessed 26 February 2015.Bruce Goldfarb,
‘HoCo Police: Dash Cams Not Used in ‘Daily Patrol Activities’ (17
April 2012) <http://patch.com/maryland/laurel/hoco-police-dash
-cams-not-used-in-daily-patrol-activi712cd2d148> accessed 26
February 2015.
4
Damon Lavrinc, ‘Why Almost Everyone in Russia Has a Dash
Cam’ (2013) <http://www.wired.com/2013/02/russian-dash-cams>
accessed 26 February 2015.
317
in the area of car insurance started in Russia when people often
became victims of staged car accidents. Seeking to protect
themselves from such frauds, drivers in Russia began mas-
sively using dashcams. It must be mentioned that in Russia,
dashcams are manufactured and distributed legally. This is a
widespread method to protect drivers’ rights when solving all
kinds of disputes related with road accidents.
Dashcams are becoming more and more popular in many
countries. Video recording helps to view traffic accidents in an
objective way: the investigation of which is often difficult and
not always objective (due to witness testimonies and mislead-
ing experts). In Europe, insurance companies may offer
discounts on insurance premiums to drivers who have in-
stalled dashcams in their cars.5 Recorded video material helps
insurance companies solve questions of damage compensa-
tion faster. But dashcams (like CCTV) could also become a
source of illegal profit when a driver, who has made a viola-
tion, may be forced to pay so that the recording does not reach
the police.6 But apart from all possible hypothetical threats,
of which the threat to personal privacy is considered to be the
biggest one, dashcams may help reach other good aims7 and
help to defend a private citizen:8 investigation of traffic acci-
dents, protection from fraud, parking accidents, record of road
crimes, recording in-car driver activity, capturing the unex-
pected, and not valid or illegal fines.
Methods of using dashcams have spread. After the reso-
nating death of Michael Brown in the USA, police officers are
starting to wear body cameras,9 which are attached to uni-
forms of police officers and allow the recording of everything
that is happening around them. The special Body-Worn Camera
Program10 prepared in the USA reasonably explains when, how
and why the body-worn cameras should be used to record
videos. As mentioned in the beginning of this article, the use
of dashcams started in US police cars. Now video recording has
5
Chris Torney, ‘Cheaper cover for drivers with dashcams’ (May
2014) <http://www.confused.com/car-insurance/articles/the-insurer
-offering-discounts-to-drivers-with-dashcams> accessed 26
February 2015.
6
Martin Robinson, ‘Corrupt policewoman who seized CCTV film
of a street bust-up to be used to blackmail Steven Gerrard is jailed
for 22 months’ (March 2015) <http://www.dailymail.co.uk/news/
article-2982837/Corrupt-policewoman-seized-CCTV-film-street-
bust-used-blackmail-Steven-Gerrard-jailed-22-
months.html#ixzz3r4hF39h1> accessed 06 November 2015.
7
Michael Jones, ‘Dash Cams – What Are The Benefits?’ (Jun 2014)
<http://blog.extended-vehicle-warranty.com/blog/dash-cams>
accessed 26 February 2015.
8
Penny Gusner, ‘7 reasons to use a dashboard camera’ (2014)
<http://www.insurance.com/auto-insurance/claims/7-reasons-to-use
-a-dash-cam.html> accessed 26 February 2015.
9
Dina Demetrius, ‘Meet the first U.S. police department to deploy
body cameras’ (December 2014) <http://america.aljazeera.com/
watch/shows/america-tonight/articles/2014/12/17/body-cams-
california.html> accessed 26 February 2015.
10
Miller, Lindsay, Jessica Toliver, and Police Executive Research
Forum, ‘Implementing a Body-Worn Camera Program: Recommen-
dations and Lessons Learned’ (2014) Washington <http://www
.fairfaxcounty.gov/bosclerk/board-committees/meetings/2015/
public-safety-body-camera-report.pdf> accessed 26 February 2015.
318 computer law & security review 32 (2016) 316–326
become a worn device. It is only a question of time when or-
dinary people will use body cameras.11
Another possibility related to the use of dashcams is public
uploading and publication of videos made with dashcams.
People who think that recordings that they have made with
their dashcams12 may interest other people who are inter-
ested in publishing the recordings so many people can view
them. Social networks on the Internet are especially well suited
for that purpose. Information that is interesting for consum-
ers spreads on social networks on the Internet extremely rapidly
– an interesting recording may be viewed thousands, mil-
lions or even a hundred million times. A private recording may
be made public in several minutes and reach any country of
the world and any consumer connected to the Internet.
3. The use of dashcams and links with the
right to privacy13
One of the biggest problems raised by the use of dashcams is
related to the right to informational privacy, private life. The
right to privacy has been known for a long time. In 1890, US
lawyers Samuel Warren and Louis Brandeis wrote a work on
a person’s right to privacy and defined it as a ‘right to be let
alone’. They were the first ones to define privacy as a social
value that must be protected by laws and judges.14
Currently, the right to informational privacy, or the invio-
lability of private life, is a right of the third generation,
established in international legal acts as well as EU docu-
ments. Article 12 of the Universal Declaration of Human Rights
indicates: ‘No one shall be subjected to arbitrary interference
with his privacy, family <. . .>. Everyone has the right to the pro-
tection of the law against such interference or attacks’.15 The
European Convention for the Protection of Human Rights and
Fundamental Freedoms also indicates: “Everyone has the right
to respect for his private and family life, his home and his
correspondence.”16
This guaranteed personal right is detailed in the General
Data Protection Directive of the EU that regulates the aspects
of information privacy, i.e. personal data protection.
Regardless of the values declared in legal documents, in prac-
tice, citizens may misuse other people’s right to informational
privacy and not only record, but also publish, recordings re-
vealing the private lives of other people. When it concerns
potential traffic violations, incidents or other potential viola-
tions, citizens often publish the supposed fact of the potential
11
Body camera added in order to show the problematic of situ-
ation in EU. If prohibit dashcams, we will not achieve anything, new
devices appear constantly, and the legal regulation not have enough
time to regulate the new devices.
12
Video as well as audio records.
13
It will examine only informational privacy, leaving out the other
elements of privacy.
14
Kiškis M., Petrauskas P., Rotomskis I., Štitilis D. Teisės informatika
ir informatikos teisė (Vilnius, 2006); p. 114.
15
UN, ‘The Universal Declaration of Human Rights’ <http://www
.un.org/en/documents/udhr/> article 12, accessed 29 March 2015.
16
Convention for the Protection of Human Rights and Funda-
mental Freedoms (1950) <http://conventions.coe.int/treaty/
en/treaties/html/005.htm> article 8, accessed 29 March 2015.
violation or incident. But the reality is that, in most cases, they
also publish material that is not related to the violation or in-
cident, i.e. the material for X period of time before the violation
or incident and the material for X period of time after the vio-
lation or incident. Thus, the right to informational privacy or
the private life of people, who had nothing to do with it, is
violated.
When assessing people’s right to privacy in the context of
the use of dashcams, it is possible to compare the benefit
created by dashcams. The benefits are obvious: the dispute is
quickly resolved; it is a cheaper solution than a long legal
process; and it can help avoid expensive experts; however, there
is the question about whether the benefits of dashcams out-
weigh the apparent threats to personal privacy.
The authors think that regardless of the practical benefit
of using dashcams, the right to privacy, private life must be
respected. It should be mentioned that the right to privacy is
not absolute, and in certain well-founded cases, it may be
limited.17 For example, when a person commits a crime in a
certain situation (when it is related to proving a committed
crime, collection of evidence, and assessment), the person’s right
to privacy may be limited. Nevertheless, in situations when
there are no legitimate circumstances to limit personal privacy
and the right to private life, privacy must be respected.
It should be mentioned that the use of dashcams as well
as publication of recordings in cyberspace are not expressly
regulated in the General Data Protection Directive. In such cases
the general principles of informational privacy and personal
data protection should be applied. The 29 WP working group
also supports this position (in its opinion on drone uses).18 But
in some countries, additional initiatives were launched to regu-
late the use of dashcams or publication of dashcam recordings.
In the next part, the authors will analyse the legal regula-
tions in the area of privacy protection of a few selected countries
and how the legal regulations is related to the use of dashcams
and publication of dashcam recordings.
4. Analysis of legal regulation in selected
countries
The authors selected three countries in the EU in which
dashcams are banned in some way and three countries in which
state institutions do not expressly regulate the use of dashcams.
It should be mentioned that all of the selected countries are
EU member states, so a uniform regime of privacy and
17
CJEU case C-112/00 Schmidberger (2003) <http://curia
.europa.eu/juris/document/document.jsf?text=&docid=47920&
pageIndex=0&doclang=EN&mode=lst&dir=&occ=first&part=1&cid
=58275> par. 80 accessed 29 September 2015.CJEU joined cases C-92/
09 and C-93/09, Volker and Markus Schecke GbR and Hartmut Eifert
v. Land Hessen (9 November 2010) <http://eur-lex.europa.eu/legal
-content/EN/TXT/HTML/?uri=CELEX:62009CJ0092&from=LT> 48 par.
accessed 29 September 2015.
18
Article 29 Data Protection Working Party Opinion 01/2015 on
Privacy and Data Protection Issues relating to the Utilisation of
Drones (2015). <http://ec.europa.eu/justice/data-protection/
article-29/documentation/opinion-recommendation/files/2015/
wp231_en.pdf> accessed 29 September 2015.
 computer law & security review 32 (2016) 316–326
personal data protection is in force in these countries, based
on the General Data Protection Directive No. 95/46/EB. Accord-
ing to this directive, member states protect the fundamental
rights and freedoms of natural persons, in particular their right
to privacy with respect to the processing of personal data.19
This Directive is applied when processing personal data wholly
or partly by automatic means or when personal data are pro-
cessed in parts and by not automatic means, when these data
form part or are intended to form part of a filing system.20 Al-
though video surveillance21 is not separately regulated in this
Directive, it is attributable to automatic processing of per-
sonal data. The Directive sets general requirements for
automatic data processing, which are based on the general prin-
ciples of privacy and personal data protection regulated in the
Directive (data quality and lawful data processing).
In Opinion 4/2004 of the Article 29 Data Protection Working
Party of the Directive, it is indicated that the principles applied
in general for video surveillance when processing personal data
should be applied also for other types of video surveillance.22
Although video surveillance with the help of dashcams is not
mentioned in the Opinion, it is obvious that the general data
protection requirements rising from the Directive should be
applicable to this type of video surveillance. Regardless of this
the authors have chosen certain EU countries for further re-
search where the use of dashcams is regulated differently.
The authors will discuss three countries that ban the use
of dashcams in some way at first.
4.1. Austria
The Austrian federal law on personal data protection23 deter-
mines data protection principles, conditions for legal use of
data, rights of data subjects, and data security means. The law
does not expressly regulate video surveillance or the use of
dashcams.
Discussions on the lawfulness of the use of dashcams in
Austria rose after a person addressed the Austrian Data Pro-
tection Authority with a wish to register dashcams. The person
planned to register himself in the register of video data man-
agers and processors in order to be able to lawfully use
dashcams in vehicles, to record his trips and possible traffic
or other (other violations that are happening near) violations
of other people with the aim of prevention (preventing your-
self from potential harm, prevention against arbitrary
circumstances) and to have video material corroborating his
19
Council Directive (EC) 95/46 on the protection of individuals with
regard to the processing of personal data and on the free move-
ment of such data [1995] article 1 p. 1.
20
Kiškis M., Petrauskas P., Rotomskis I., Štitilis D. Teisės informatika
ir informatikos teisė (Vilnius, 2006) 114.
21
Authors include video surveillance category as such, it in-
cludes a simple video surveillance cameras indoors and others.
22
Article 29 Data Protection Working Party, ‘Opinion on the Pro-
cessing of Personal Data by means of Video Surveillance’ (2004) WP
89 <http://ec.europa.eu/justice/policies/privacy/docs/wpdocs/2004/
wp89_en.pdf> accessed 01 April 2015.
23
Federal act concerning the protection of personal data
Bundesgesetz über den Schutz personenbezogener Date (2000)
<https://www.dsb.gv.at/DocView.axd?CobId=41936> accessed 19 April
2015.
319
account of the accident. If people see cars with stickers (if it
is an obligation to mark cars) they will behave more respon-
sibly because they know that they are observed. In their decision
the Austrian Data Protection Authority24 explained that the use
of dashcams in vehicles was not the same as making video
recordings of one’s own surroundings. The right to video re-
cording encompasses a certain surveyed area which is known
and an announced surveillance area (a person has the right
to watch the property owned), whereas a car is a moving object
that enters other public spaces, the surveillance of which in
Austria is exclusively the monopoly of the state. It can be seen
that only the police and other public institutions may use tech-
nical equipment for video processing for administrative
procedural purposes.25 Also, this decision indicates that video
surveillance using dashcams in vehicles cannot be called video
surveillance because the mentioned concept is defined in the
law on data protection and is understood as stationary equip-
ment, the use of which is notified, thus there is no risk for other
people to enter such video recording territory without knowing
it. The Data Protection Authority states that the request to reg-
ister the use of dashcams in vehicles does not meet the
principle of the purpose and proportionality of video recording.
As a result, this decision by the Austrian Data Protection
Authority practically banned the use of dashcams in Austria.
Based on the decision of the Data Protection Authority, all
drivers who use dashcams in their cars may be penalised by
a fine of 10,000 EUR, repeatedly even by a fine of 25,000 EUR,
and other people who have been recorded by dashcams may
ask for compensation of even up to 20,000 EUR.
It is important to mention that video recording after a traffic
accident is not forbidden. A person has the right to gather evi-
dence that may help to protect him, when solving the question
of guilt. Such a situation may be explained by giving the fol-
lowing example: the use of dashcams for prevention purposes
in cars is forbidden, but after a traffic accident, all road users
may record evidence by means acceptable to them, i.e. when
video recording is performed after an accident, and the re-
corded image encompasses the scene of the accident, the
damaged property and the victims, such recording is allowed.
On 30 January 2015, the Federal Administrative Court dis-
missed a similar complaint26 and left the earlier adopted
decision of the Data Protection Authority in force: dashcams
in cars are forbidden.
A conclusion may be made that, regardless that the use of
dashcams in Austria is not expressly regulated, it is forbid-
den to use dashcams in Austria. It was not possible to find any
case law or documents on the publication of video record-
ings made with dashcams by the Data Protection Authority.
24
Bescheid Zahl K600.319-005/0002-DVR/2012 vom 7 (November
2012) <https://www.ris.bka.gv.at/Dokument.wxe?Abfrage=
Dsk&Dokumentnummer=DSKTE_20121107_K600319_005_0002_DVR
_2012_00> accessed 26 March 2015.
25
Sicherheitspolizeigesetz (SPG), BGBl. Nr. 566/1991 <https://
www.ris.bka.gv.at/Dokument.wxe?Abfrage=Bundesnormen&
Dokumentnummer=NOR40136947> accessed 26 March 2015.
26
Zahl W214 2011104-1/9E (Jänner 2015), Zahl D610.000/0002-DSB/
2014 vom 23 (2014) <https://www.dsb.gv.at/site/8105/default.aspx>
accessed 26 March 2015.
320 computer law & security review 32 (2016) 316–326
4.2. Germany
The Federal Data Protection Act of Germany27 does not ex-
pressly regulate video surveillance or dashcams. The law
establishes the general principles related to the lawful basis
for data processing and the right of a data subject.
The question of lawfulness with the use of dashcams in
Germany arose after litigation where the accused indicated a
video recording made by him proved he was innocent and con-
firmed his position that another road user was guilty. But the
Heilbronn County Court had another opinion: it indicated that
when a hidden video recording was made, the main right to
informational self-determination was violated. The term “right
to informational self-determination” was first used in a German
constitutional decision in 1983.28 The Federal Constitutional
Court of Germany indicated that it was necessary to protect
personal privacy in contemporary data processing, to control
unlimited information gathering, storage, use and revealing as
a constitutional value. A person is guaranteed the right in prin-
ciple to determine how to disclose and use personal data. This
right can be limited only for protection of a superior public in-
terest. The right to informational self-determination is often
seen as synonymous to the right to privacy, but the right of
informational self-determination includes the possibility to
choose what information about a person should be commu-
nicated to others and under what circumstances. In the
mentioned decisions of the Heilbronn Country Court, this right
was taken into account when evaluating the legitimacy of digital
evidence. The Court did not accept the video recording as evi-
dence reasoning that the use of dashcams in cars violated the
right of others to informational self-determination (the right
to privacy).29
The Ansbach Administrative Court also decided that
dashcams are incompatible with the German legal acts on data
protection; as a result of this decision, the Bavarian Personal
Data Protection Authority passed a decision that raised many
discussions: if drivers give over video recordings made with
their dashcams to the police, insurance companies and similar
organisations, or publish them on the Internet, in each spe-
cific case they may be penalised by a fine of even up to 300,000
EUR.30
Although no special legal norms to forbid the use of
dashcams or publication of recordings have been passed in
Germany, case law is fairly principled when interpreting the
27
Federal Data Protection Act Gesetz zum Schutz vor Mißbrauch
personenbezogener Daten bei der Datenverarbeitung (1990).
<http://www.iuscomp.org/gla/statutes/BDSG.htm> accessed 19 April
2015.
28
András Jóri, ‘The census decision and the second generation of
data protection norms’ (February 2007) <http://www.dataprotection
.eu/pmwiki/pmwiki.php?n=Main.SecondGeneration> accessed 26
March 2015.
29
Aufnahmen von Dashcams im Zivilprozess (20 February 2005)
<http://www.baden-wuerttemberg.datenschutz.de/wp-content/
uploads/2015/02/Aufnahmen-von-Dashcams-im-Zivilprozess
.pdf#> accessed 26 March 2015.
30
Thomas Kranig, ‘Pressemitteilung des Bayerischen Landesamtes
für Datenschutzaufsicht vom 06.10.2014’ (2014) <https://
www.lda.bayern.de/lda/datenschutzaufsicht/p_archiv/2014/
pm013.html> accessed 26 March 2015.
general legal norms on privacy. The latest court decisions
support the concept of forbidding the use of dashcams and
using publications of video recordings made with them.
4.3. Luxembourg
The law on data protection of Luxembourg of 200231 regu-
lates video surveillance only in cases when public places need
to be surveyed with the purposes of crime prevention and in-
vestigation. But video surveillance in general, including the use
of dashcams, is not expressly regulated in Luxembourg.
The National Commission for Data Protection in 2013 ad-
dressed the issue of the lawfulness of using video cameras.32
The Commission notes that the use of such video cameras (as
well as dashcams in cars) is unlawful when they are directed
towards a public space and may record people who may later
be recognised in the recording. It is noted that the main purpose
of such equipment is to record traffic, seeking to identify the
guilty party in case of a traffic accident. There is no possibil-
ity to separate the fixed and mobile video recording (the variety
of devices and their use), so, apart from recording traffic images,
people, transport vehicles, and their licence plates are also re-
corded, and this is already the processing of personal data. In
this case to seek to perform such surveillance and recording,
it is necessary to receive a permit from the Commission of Data
Protection. Such a permit for data processing is issued only for
a sufficiently serious reason. The law on personal data of Lux-
embourg does not foresee such possibility; no aims are foreseen
in the Law that would justify the use of such video cameras
(when they are used not by special services).
The use of dashcams is considered to be disproportionate
when all road users in public spaces may be filmed without
knowing it. Also, it is impossible to comply with the obliga-
tion foreseen in the legal acts to inform the surveyed people.
Although the inside of a vehicle is considered to be private
space, it is forbidden to film from a vehicle into a public space.
The Commission of Data Protection has indicated that only the
use of dashcams in public spaces is unlawful, but the use of
the device itself is completely lawful. Besides, it is noted that
dashcams should not be confused with parking assistance
cameras that help drivers park a car, sending the image di-
rectly from the outside of a car – the purpose of such devices
is different.
Although there are no special legal acts in Luxembourg that
ban the use of dashcams, the position of the responsible in-
stitution is sufficiently principled and clearly shows that the
use of dashcams in Luxembourg is forbidden.
Also, three other selected countries should be discussed
where the legislator or state institutions do not expressly regu-
late the use of dashcams.
31
Law on the Protection of Persons with regard to the Process-
ing of Personal Data (2002) <http://www.cnpd.public.lu/fr/legislation/
droit-lux/doc_loi02082002_en.pdf> accessed 19 April 2015.
32
Die nationale Kommission für den Datenschutz (CNPD).
Dashcams Sind Videokameras in Autos legal? (2013) <http://www
.cnpd.public.lu/de/actualites/national/2013/06/cameras-voiture/
index.html?highlight=%C3%9Cberwachung> accessed 26 March 2015.
 computer law & security review 32 (2016) 316–326
4.4. United Kingdom
Legal acts in the United Kingdom do not foresee the ban on
the use of video recording equipment in cars. Although video
recording in cars has similarities with using CCTV at home,
there is an essential difference – the purpose of the recording.33
The purpose of using CCTV at home is active prevention, de-
terring potential thieves from crime, and such video surveillance
is justifiable. There are no legal means to ban the installation
of CCTV unless it is proven that such systems may intrude on
privacy in places where people reasonably expect privacy of
personal space. It is understandable that in public spaces or
on public roads a person cannot expect total privacy. The biggest
value of video cameras is public interest that may be pro-
tected using a video recording where a violation or a crime is
seen. Police institutions have been using such video record-
ing means for a long time already.
General road safety requirements are raised for dashcams
in vehicles: it must not block the view to the driver, must not
distract, and must not pose a threat to road users (it must be
well attached). It is recommended for a dashcam to start and
stop operating together with the turning on and off of the ig-
nition, so that their switching on and off would not distract
drivers.
The Data Protection Act of the United Kingdom34 regu-
lates how organisations, enterprises or state institutions use
personal information. Therefore, for example, taxi compa-
nies must indicate that sound is recorded inside their vehicles
so that passengers would not expect privacy in such cars.
Whereas, dashcam use in vehicles of natural persons is not
expressly regulated by the mentioned legal act, and the general
data protection principles, foreseen in the law as well as its
first annex, should be applied to their use.35
4.5. Belgium
The Belgian law on privacy protection in relation to the pro-
cessing of personal data36 determines the general principles
of privacy protection and implements the General Data Pro-
tection Directive, not expressly regulating the questions of video
surveillance.
The Belgian Commission for the Protection of Privacy an-
nounced the guidelines of using dashcams in vehicles in 2014.37
The guidelines indicate that dashcams often become an at-
tribute in personal vehicles. People have started to record their
trips more often, and they often publish their video record-
ings on the Internet. The publication of video material raises
33
David Barton, ‘Dashcam – the new must have accessory?’ (2014)
<http://www.motorists-lawyer-kent.co.uk/resources/filer.rhtm/754905/
dashcam+-+the+new+must-have+accessory.pdf> accessed 29 March
2015.
34
UK Data Protection Act 1998 <http://www.legislation.gov.uk/
ukpga/1998/29/contents> accessed 29 March 2015.
35
Ibid sShedule 1.
36
The law on privacy protection in relation to the processing of
personal data 1992 <https://clientsites.linklaters.com/Clients/
dataprotected/Pages/Belgium.aspx> accessed 29 March 2015.
37
Commission for the Protection of Privacy, ‘Dashcams’ (2014)
<http://www.privacycommission.be/nl/dashcams> accessed 29
March 2015.
321
concerns if privacy and data protection rules should be applied
to recorded video material. The guidelines of the Privacy Com-
mission distinguish the three main purposes of using dashcams:
leisure and entertainment, recording of traffic accidents and
gathering of evidence, and dashcams in taxicabs.
The Belgian privacy and data protection rules will not be
applied to dashcams used in Belgium for leisure and enter-
tainment. An important condition is that such recorded video
information will be used with a narrow circle of people and
only with personal purposes. If a person publishes such a video
recording for a wider audience on the Internet, that person will
be considered a data manager, and regulations foreseen in legal
acts will be applicable to him (proportionality requirement, duty
to inform others about video recording, registration as a domain
manager, and covering faces of other people seen in the video).
In the case of recording traffic accidents and gathering evi-
dence, dashcams are used for a certain purpose to collect visual
information that may become evidence in judicial proceed-
ings. Everybody has the right to collect evidence, but collection
of such information (legal information as evidence) falls under
the exceptions of the data protection law, when it is allowed
to collect data for specified, explicit and legitimate purposes.38
In such a case, a person must prove that the collection of such
information may be necessary in litigation to protect his rights.
In such situations owners of dashcams become data manag-
ers and must correspond to the information collection
proportionality principle. In fact, that means that if no inci-
dent is recorded, the video recording must be deleted at once
(e.g. after each ride, at the end of the day). And if a traffic ac-
cident happens, other road users must be informed at once
about the recording done or being done by a dashcam. Also,
drivers using dashcams for such purposes will have to regis-
ter with the Belgian Privacy Commission.
Companies that provide taxi services seeking to protect their
drivers and property may install dashcams in their taxi ve-
hicles. The law on personal data protection will not be applied
to taxi companies; they fall under the Belgian Surveillance
Camera Act.39 The Belgian Surveillance Camera Act foresees
specific requirements on storing, accessing and using re-
corded video information. Also, taxi companies must register
with the Belgian Privacy Commission. Taxis with dashcams
must be marked with special signs that video and sound re-
cording is performed.
In Belgium, the use of dashcams is allowed, and when a re-
cording made with a dashcam is published, the person is
considered to be a data manager, and personal data protec-
tion principles, foreseen in the Belgian law on privacy protection
in relation to the processing of personal data in force, are
applied to that person.
38
Royal Decree implementing the Act of 8 December 1992 on the
protection of privacy in relation to the processing of personal data
<http://www.privacycommission.be/sites/privacycommission/files/
documents/Royal_Decree_2001.pdf> accessed 29 March 2015.
39
Unofficial translation of the Belgian Surveillance Camera Act
of 21 March 2007 <http://www.slideshare.net/Johan_Vdd/unofficial
-translation-of-the-belgian-camera-surveillance-act> accessed 29
March 2015.
322 computer law & security review 32 (2016) 316–326
4.6. Lithuania
In Lithuania the Law on Legal Protection of Personal Data of
the Republic of Lithuania, passed in 1996, is applicable.40 In this
law video surveillance is defined as “processing of image data
concerning natural person (hereinafter referred to as ‘image
data’) by using automated video surveillance means (video and
photo cameras, etc.) irrespective of whether these data are re-
corded in a file or not.”41 Chapter III of this law is on video
surveillance. According to Article 16 of the law, “Video surveil-
lance may be used for the purpose of ensuring public safety,
public order and protecting person’s life, health, property and
other rights and freedoms of persons but only in these cases
when other ways or measures are insufficient and (or) inad-
equate for the achievement of the above mentioned purposes
unless they are overridden by the interests of the data subject.”42
But it is necessary to mention that according to page 4 of Article
1 of the law, “This Law shall not apply if personal data are pro-
cessed by a natural person only for his personal needs not
related to business or profession.”43 That means that when data
processing passes the boundaries of personal needs, all norms
of the Law should be applied to the actions by a person pro-
cessing personal data.
The case law in Lithuania does not contradict this posi-
tion. By the Order of 29 October 2010 of the Supreme
Administrative Court of Lithuania in administrative proceed-
ings No. N-62-2622/2010,44 it was stated that R. A. bore no
administrative responsibility according to the Code of Admin-
istrative Offences of the Republic of Lithuania. All the violations
of the Law on Legal Protection of Personal Data of the Repub-
lic of Lithuania incriminated to R. A. were not applicable because
the Institution did not prove that R. A. was a data processor
or manager and that she processed personal data of J. M. not
for personal needs. It should be considered that such prac-
tice of the Supreme Administrative Court creates possibilities
in certain cases, when video surveillance passes the limits of
personal needs, and the actions of a person may be treated
as the actions of a data manager, and they may be qualified
as a violation.
In February of 2014, the Lithuanian State Data Protection
Inspectorate organised a discussion on video recorders.45 Rep-
resentatives of the Ministry of Transport and Communications,
Public Security Policy Department of the Ministry of the Inte-
rior, and the Police Department under the Ministry of the
Interior participated in the meeting. The problems of the use
of recorders and personal data management when using traffic
recorders in vehicles were discussed. It was decided during the
meeting that video recorders in cars are especially useful when
40
Law on Legal Protection of Personal Data of the Republic of Lithu-
ania (1996) <http://www3.lrs.lt/pls/inter3/dokpaieska.showdoc
_l?p_id=400103> accessed 29 March 2015.
41
Ibid. Article 2, p. 17.
42
Ibid. Article 16.
43
Ibid. Article 1, p. 4.
44
Order of the Supreme Administrative Court of Lithuania in ad-
ministrative proceedings N62-2622/2010 <http://www.infolex
.lt/tp/176447> accessed 29 March 2015.
45
Lithuanian State Data Protection Inspectorate Discussion on
Video Recorders (2014) <https://www.ada.lt/go.php/lit/Diskusija-
del-vaizdo-registratoriu/167> accessed 29 March 2015.
solving arising conflicts where road users cannot properly agree.
According to the Director of the Lithuania State Data Protec-
tion Inspectorate, dashcams should be allowed in Lithuania,
but publication of data recorded with dashcams may be treated
as a violation of personal rights. It is possible to publish and
announce data collected this way only after receiving agree-
ments of the people who were filmed. When a driver installs
a dashcam in his car in Lithuania, data collected are treated
as information collected with personal purposes, and the law
on data protection is not applicable. Company cars are another
case. If a dashcam is installed in a company car, then the
company becomes a manager of collected data, and in this case,
the provisions of the Law on Legal Protection of Personal Data
would be applicable – such a company must register with the
State Data Protection Inspectorate as a data controller.
At the beginning of 2014, the State Data Protection Inspec-
torate planned to determine the same rules for all users of
dashcams in Lithuania, i.e. it was stated that it would be regu-
lated how and in what cars it would be allowed to use
dashcams, and what their legal status would be.46 But re-
cently, the Inspectorate renounced the thought to regulate
additionally the use of dashcams. In Lithuania at the moment,
the use of dashcams is still not regulated but, according to the
Director of the Inspectorate, these devices are already mounted
in all new buses.
In summary, in Lithuania the use of dashcams including
publication of their recordings is allowed. But publication of
recordings may be treated as a violation if the principles of per-
sonal data protection set in Lithuanian laws are not kept.
Summarising the performed research, the received results
are presented in Fig. 1.
5. Legal regulation of the use of dashcams:
the search for a balance
As can be seen from the research of the legal regulation of the
use of dashcams in certain countries, despite a harmonised
EU data protection system arising from the General Data Pro-
tection Directive of 1995, the practice of separate EU countries
on the use of dashcams and the publication of recordings
differs.
Such different practices once more show that regardless of
the General EU Data Protection Directive of 1995 and its norms
and principles in force, corresponding legal regulation in dif-
ferent EU countries may, in principle, be different. Because of
that, the European Commission submitted a proposal for the
Regulation on Data Protection47 in 2012, which is currently under
final adoption phase. The Regulation will be applicable in all
46
The use of video recorders is planned to be regulated in
Lithuania (2014) <http://kauno.diena.lt/naujienos/verslas/ratai/
lietuvoje-ketinama-reglamentuoti-videoregistratoriu-naudojima
-613286#.VTkdCXmKCM9> accessed 29 March 2015.
47
European Commission Proposal on the protection of individu-
als with regard to the processing of personal data and on the free
movement of such data (2012) <http://ec.europa.eu/justice/
data-protection/document/review2012/com_2012_11_en.pdf>
accessed 29 March 2015.
 computer law & security review 32 (2016) 316–326 323

Fig. 1 – Summary of the results. Compiled by the authors.

EU Member States directly, so a more uniform practice should
be ensured.
When analysing the provisions of the Regulation, it should
be noted that video surveillance in itself is not regulated ex-
plicitly and the legislators of EU normative acts are not planning
to regulate video surveillance separately, especially video sur-
veillance with the help of dashcams. Therefore, after the final
adoption of the Regulation,48 the use of dashcams should be
assessed based on the general personal data protection prin-
ciples of the Regulation.
48
Final adoption is planned for the beginning of 2016.
The question may arise if the existence of the Regulation
will create conditions for countries to additionally regulate the
corresponding area – the use of dashcams. The answer is prob-
ably yes, if that will not contradict the provisions of the
Regulation. But it should be discussed if additional legal regu-
lation of the use of dashcams is necessary on the whole,
especially banning the use of dashcams partially or fully.
The authors think that the use of dashcams, as well as pub-
lication of dashcam recordings, should not be forbidden, but
requirements of the legal acts in force should be complied with.
The applied general personal data protection principles should
be sufficient for assessment of the use of dashcams, includ-
ing publication of dashcam recordings. Even the principles that
324 computer law & security review 32 (2016) 316–326
Fig. 2 – Practical benefit of dashcams and threats to privacy:
the balance. Compiled by the authors.
are now set in the General Data Protection Directive should
be sufficient. That would also help to ensure a balance between
the rights of a certain person, mentioned in Fig. 2, and the rights
of others to privacy and personal data protection.
According to the authors, in the context of dashcam use,
the following principles of the General Data Protection Direc-
tive are especially important: data quality, lawful processing
of personal data, proportionality, data subject rights, domain
safety, and transparency.
The data quality principle could be applied in the context
that a dashcam recording would not pass the set initial aims.
For example, if the aim was to record traffic accidents, the part
of the recording that is not related to the traffic accident should
not be processed further, especially as regards publication of
the dashcam recording.
The principle of lawful data processing could be applied in
the context when the basis for lawful personal data process-
ing should be assessed. In the case of recording a violation,
according to the authors, the right of the dashcam user to record
a violation should outweigh the right of others to privacy (the
principle of lawful interests). And when publishing such a re-
cording, it should be made anonymous unless the agreement
of people that had been filmed was received.
The principle of proportionality should ensure that, for
example, when a recording is published after a violation is re-
corded, only the recording related to the violation should be
published and not additional elements of the recording not
related to the violation. In other words, the duration of such
a recording should correspond to the main recording purpose
and should not exceed it.
The principle of data subject rights should ensure man-
agement of practical situations, when, for example, a dashcam
recording with a person not related to the violation and who
happened to get onto the recording accidentally is published.
Such a person could demand not to process the personal data
related to this person. The requirement to inform about a video
recording being made could be foreseen as a prevention
measure for possible problematic situations. This could be a
sign with an agreed form on it, a sticker or a writing on the
outside of the vehicle. The principle of transparency would also
be implemented in this way.
The application of the data security principle should ensure
that dashcams will not be freely accessible, i.e. the vehicle will
be locked when the owner is away, and video recordings will
be stored on a computer, and sufficient technical protection
of the computer and the recordings will be ensured. One of the
methods of the technical solution could be a setting for re-
cording length, i.e. most dashcams can record videos in intervals
(of 5, 10, 15, 30 minutes), and after the end of the interval a
new recording starts, and as the number of recordings in-
creases, new recordings automatically change older ones, and
after a traffic accident, the owner can transfer the recording
for further use. Thus, it can be ensured that the dashcam re-
cording will not be stored for too long.
A counterargument may be mentioned that personal data
protection regulation and corresponding personal data pro-
tection principles cannot be applied to video surveillance for
personal purposes. But, according to the authors, the prin-
ciples could ensure protection of certain people in cases when
video surveillance passes the limits of surveillance for per-
sonal purposes and violates the rights of others. In such cases
the indicated personal data protection principles, including cor-
responding legal norms implementing the principles, should
be applied, thus ensuring a balance between a person’s right
to privacy as well as personal data protection and other men-
tioned personal rights.
Self-regulation mechanisms are significant for the imple-
mentation of the above-mentioned purposes in practice.
According to the authors, dashcam manufacturers could and
should contribute to achieving certain aims, technically and
programmatically limiting the possibility to violate the above-
mentioned principles (e.g. by determining that each new video
recording would be done in the place of an old recording, lim-
iting the length of recordings, etc.).
If nevertheless most EU countries decide to support the ban
to use dashcams, they would encounter new problems. Many
technological devices (telephones, tablet computers, watches)
have a possibility to record videos, and the ban in force will
not encompass all these technological novelties. New devices
are being created (such as Quadcopters, Bodycam), having the
possibility to record videos and sound, and the present ban will
limit the manufacture and development of such technologi-
cal devices. It is not appropriate to prohibit the use of dashcams,
because their functions can be performed by other devices.
6. Conclusions
The most important purpose of using dashcams is the pre-
vention and protection of private and public interest that
encompass the investigation of traffic accidents, protection from
fraud, parking accidents, the record of road crimes, recording
in-car driver activity, capturing the unexpected, and not valid
or illegal fines.
Sometimes data collected with dashcams are published after
some incidents or violations. There is only the subjective and
incorrect opinions of many people that a recorded violation
outweighs the right of others to privacy, and this creates a pos-
sibility for citizens to violate other people’s right to privacy and
not only to record but also to publish a recording that reveals
 computer law & security review 32 (2016) 316–326
another person’s private life. It is a challenge to enforce privacy
rules in such situations.
Despite a uniform EU data protection system, analysis in
the selected countries has shown that the treatment of dashcam
use in separate countries and/or publication of dashcam re-
cordings differ substantially. The legislator of EU normative acts
is not planning to regulate video surveillance separately, es-
pecially video surveillance with the help of dashcams.
There is no unanimous opinion on the lawfulness of the
use of dashcams. Countries that do not ban their use indi-
cate that there are no legal means to ban video recording if
there is no infringement on private, personal life in areas where
they reasonably expect privacy of personal space and public
interest, which may be defended by using a recorded video,
proves the benefit of dashcams.
In case of the publication of data collected with dashcams
after an incident or violation, it should be evaluated if the prac-
tical benefit of dashcams outweighs the apparent threats to
privacy. Regardless of the practical benefit of using dashcams,
the right to privacy and private life remains and must be re-
spected, but it should be also taken to account that the right
to privacy is not absolute, and in certain well-founded cases,
it may be limited.
The use of dashcams and publication of their recordings
should not be forbidden. Owners of dashcams should adhere
to the principle of proportionality of information collection, and
if video surveillance passes the indicated prevention limits and
may violate rights of other people, the principles of personal
data protection should be applied in full, including the legal
norms implementing the corresponding principles, thus en-
suring a balance among the right of people to privacy and
personal data protection.
With different regulation of dashcams present in EU coun-
tries, dashcam manufacturers should also contribute to the
solution of this problem. With regard to data protection prin-
ciples, manufacturers can technically and programmatically
limit the possibilities of dashcam misuse.
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Darius Stitilis is a professor at the Mykolas Romeris Univer-
sity (e-mail: stitilis@mruni.eu). He obtained PhD degree in law
from Mykolas Romeris University in 2002 (the topic of PhD
Thesis was related to the legal responsibility in cyberspace).
He is the executive manager of master study programs at
Mykolas Romeris University: Internet and technologies law,
Cyber security management. His research interests include IT
law, cyber security law, privacy and personal data protection
law, electronic identification law, cybercrime, electronic com-
merce law. He has over 40 publications primarily in the field
of law and IT. Under his direction, he was involved in several
scientific EU and national projects. Also, he is the co-author
of scientific monograph regarding identity theft in cyber-
space: legal and electronic business issues.
Marius Laurinaitis is a lecturer at Mykolas Romeris Univer-
sity. He obtained PhD degree in law from Mykolas Romeris
University in 2015 (the topic of PhD Thesis was related to the
Legal Regulation of Electronic Money). He is the executive editor
of International Scientific Research Journal “Intellectual Eco-
nomics”. His research interests include IT law, privacy and
personal data protection law, electronic identification law, elec-
tronic payments law, electronic money. He has over 10
publications primarily in the field of law, financial services and
IT. He is the co-author of scientific monograph regarding
identity theft in cyberspace: legal and electronic business
issues.