FEBRUARY 02, 2024

Digital Image Collection: New Poster.

CIRCULARS

Data Privacy & Data Protection – Cybersecurity Department Report | Digital Image Collection: New Poster

Resolution No. 38/2024 of the Agency for Access to Public Information (AAPI), published in the Official Gazette today, amends Provision No. 10/2015, which establishes the conditions of lawfulness for the collection and subsequent processing of digital images of individuals for security purposes, given that the image or film recording constitutes personal data according to Personal Data Protection Law No. 25.326 (“DP Law”) since the person can be identified or identifiable.

Among other obligations, Provision No. 10/2015 establishes that the existence of security cameras must be disclosed to the public (without the need to specify their current location) by using a poster in the facilities. Through Resolution No. 38/2024, the AAPI approved, under Annex I, the new design model of the poster that can be used in the case of digital image collection, in compliance with the requirement of prior information to the data subject established in the conditions of lawfulness, replacing the model approved by Provision No. 10/2015. The new design model of the poster n is the following:

Cartel Anexo Resolución N°38/2024

Cartel Anexo Resolución N°38/2024

Do not hesitate to contact us if you require any further information on this matter.

Sincerely,

Emilio Beccar Varela
Florencia Rosati