The President of the Personal Data Protection Office intervenes regarding body-worn cameras used by ticket inspectors

The President of the Personal Data Protection Office, Mirosław Wróblewski, has written to the Minister of Infrastructure, Dariusz Klimczak, requesting that action be taken to ensure the effective application of personal data protection regulations in relation to the use of body-worn cameras by ticket inspectors.

Currently, the provisions of generally applicable law do not contain any rules regulating this matter. Meanwhile, surveillance using devices that record sound or images is an intrusive form of personal data processing and poses a threat to the rights and freedoms of individuals.

In the opinion of the President of the Personal Data Protection Office, the provisions of the Transport Law and the Act on Public Passenger Transport do not contain legal provisions that could be regarded as a comprehensive legal basis, compliant with the requirements of the GDPR, for the processing of personal data using devices employed during ticket or travel document checks. Meanwhile, the provisions of the GDPR require a clearly defined legal basis for processing that is consistent with the constitutional order, covering in particular the purpose of the processing of personal data.

 In response to a letter sent by the President of the Personal Data Protection Office, the Ministry of Infrastructure concurred with the supervisory authority’s position and acknowledged that neither the Transport Law nor the Act on Public Passenger Transport grants the carrier, organisers or persons authorised by them the right to use body-worn cameras when checking passenger and luggage transport documents.

In view of the questions and needs of public transport organisers, the President of the Personal Data Protection Office declares a willingness to cooperate with the Ministry of Infrastructure in this regard.

DPNT.413.14.2025