PrivCom releases the first of a series of guidance notes on recording in public

The Office of the Privacy Commissioner for Bermuda (PrivCom) is announcing the release of a new series of guidance notes focused on recording in public places and the use of closed-circuit television (CCTV) and other types of cameras such as doorbell, ring and dash cameras. The guidance is designed to increase general understanding of the rights of individuals under Bermuda’s data privacy law, the Personal Information Protection Act 2016 (PIPA), and to help organisations better understand their obligations under PIPA.

As the use of cameras, smartphones, and surveillance technologies continues to grow, questions around privacy, consent, transparency, proportionality, accountability, and the application of PIPA are becoming increasingly common. PrivCom’s guidance notes provide practical advice on how to balance individuals’ fundamental right to personal privacy with legitimate uses of personal information by organisations in Bermuda.

The series covers the following themes:

• Recording at public events, Part 1: Individuals

• Recording at public events, Part 2: Organisations

• CCTV, ring, doorbell and other cameras, Part 1: Individuals

• CCTV, ring, doorbell and other cameras, Part 2: Organisations

• Dashcams, Part 1: Individuals

• Dashcams, Part 2: Organisations

The following subtopics will be included:

• lawful, fair, transparent, and responsible use of CCTV and other cameras;

• the responsibilities of organisations and individuals who capture photographic or videographic footage;

• the rights of individuals who may be recorded.

“The goal of these guidance notes is to provide clarity for both individuals and organisations, to support organisations’ compliance with PIPA, and to promote responsible, transparent and ethical privacy practices across Bermuda,” said the Acting Privacy Commissioner Farquharson. “Whether you are a business owner installing CCTV or an individual recording in a public place, it is important to understand how PIPA applies and how to respect the privacy rights of individuals.”

PrivCom encourages organisations to review their current practices in light of the new guidance and to use the guidance notes as a resource when developing or updating policies related to recording and CCTV use.

Part 1 of the first guidance note on recording people at public events is available on PrivCom’s website. The remainder of the guidance notes will be release in 2026 as part of an ongoing initiative to raise awareness of the topic and increase general understanding of individual rights and organisational responsibilities and obligations under PIPA.

For more information, visit PrivCom’s website at www.privacy.bm or call PrivCom at 573-7748.