Serbia’s MoI Should Suspend the Introduction of Smart Video Surveillance Systems

Data Protection Impact Assessment for Video Surveillance developed by Serbia’s Ministry of Interior (MoI) does not meet the formal or material requirements laid down by the Law on Personal Data Protection, which is why the MoI should suspend the introduction of smart video surveillance systems.

Civil society organizations SHARE Foundation, Partners for Democratic Change Serbia and the Belgrade Centre for Security Policy (BCSP) have analyzed in detail the Data Protection Impact Assessment for Video Surveillance provided by the MoI to the Commissioner for Information of Public Importance and Personal Data Protection.

Organizations believe that the MoI Impact Assessment does not meet the minimum statutory requirements because:

• Methodology and the structure of the Impact Assessment do not comply with the requirements envisaged by law;
• There is no comprehensive description of the envisaged personal data processing operations;
• No risks to citizens' rights and freedoms were assessed;
• The measures that are intended to be taken in relation to the existence of risks are not described;
• The technical, organizational and personnel measures for the protection of personal data are described only in part.

The legal basis for the massive use of smart video surveillance is also controversial, while the positive effects on crime reduction outlined in the Impact Assessment are overestimated by the selective use of relevant research and comparative practices.

The Impact Assessment did not establish that the use of smart video surveillance is necessary for the sake of public safety, nor that the use of such invasive technology is proportionate, given the risks to citizens' rights and freedoms.

Although the Impact Assessment contains examples of countries that rely heavily on video surveillance, it is neglecting the growing trend of banning or restricting such systems worldwide, because of the identified risks.

Because of all this, SHARE Foundation, Partners for Democratic Change and the Belgrade Centre for Security Policy (BCSP) are calling on the MoI to suspend the introduction of smart video surveillance systems, and emphasize the need for a broad public debate on the needs, effects and possible consequences of introducing such a system.