Argentine Data Protection Authority updates CCTV signs
By Mariano Peruzzotti, Candela Basilotta and Andrea Sánchez Vicentini
On February 2 of 2024, Resolution 38/2024 (“Resolution”) of the Agency for Access to Public Information, the supervisory body of the Personal Data Protection Law (“AAPI”), was published in the Official Gazette. This Resolution modifies Provision 10/2015 of the previous National Directorate of Personal Data, which regulates the activities of collection and subsequent processing of digital images of people for security purposes.
Provision 10/2015 establishes in its article 1 that the collection of digital images of people through security cameras will be lawful to the extent that it has the prior and informed consent of the data subject. To this end, the controller may use signs that clearly indicate to the data subjects the existence of the devices, the purposes of capturing images and the controller in charge of the treatment with their address and contact information for the correct exercise of the data subject’s rights.
In particular, the Resolution incorporates a new design model for the mandatory signs that, in this version, includes an express mention of the rights of access, rectification and deletion of personal data. In addition, the following text is included: “If you do not receive a response or it is unsatisfactory, visit www.argentina.gob.ar/aaip/datospersonales or scan the QR and learn more.”
This is the third version of the informational poster design.
The text of the Resolution that includes the annex with the new design can be found at the following link.
For more information on the legal conditions for the activities of collecting and processing digital images of people for security purposes, contact mperuzzotti@ojambf.com, asanchezvicentini@ojambf.com and cbasilotta@ojambf.com.
