## Facts

- František Ryneš installed a CCTV camera on his family home after repeated vandalism, including broken windows.
- The camera filmed the home’s entrance and also captured a public footpath and the entrance to a neighboring house.
- The system continuously recorded and stored footage on a hard drive inside the home; Ryneš alone accessed the recordings.
- Passers-by were not informed that they were being recorded.
- After a new attack, footage helped identify two suspects; Ryneš gave the recording to police for use in criminal proceedings.
- A suspect complained to the Czech data protection authority, which found Ryneš to be a data controller who had processed personal data without meeting information and notification obligations under national law implementing Directive 95/46/EC.
- National litigation led the Czech Supreme Administrative Court to refer questions to the Court of Justice of the European Union on whether the household exemption applied.

## Issues

1. Whether video footage of individuals recorded and stored by a home CCTV system constitutes “processing of personal data” within the scope of Directive 95/46/EC.
2. Whether the “purely personal or household activity” exemption applies when a home CCTV system records areas of public space.

## Decision

- The court held that images of persons recorded by a camera are personal data when the persons can be identified, and recording and storing such footage is processing by automatic means covered by the Directive.
- The court held the household exemption does not apply where surveillance covers, even partly, a public space and is directed outward from the private sphere.
- The court returned the dispute to the referring court to apply the Directive’s substantive requirements and determine lawfulness on the facts.

## Legal Principles

- Camera images that allow identification of a person qualify as personal data.
- Continuous or systematic recording and storage of such images by a CCTV system constitutes processing of personal data by automatic means.
- The household exemption is construed narrowly; it covers activities confined to private life and does not extend to processing that reaches outside the private sphere into public space.
- Even when the Directive applies, national courts must assess whether processing can be justified under applicable legal bases (including legitimate interests) and must consider proportionality and compliance duties (such as transparency and any required notification).

## Conclusion

Home CCTV that captures any part of public space falls within EU data protection rules and is not excluded as a purely personal or household activity; whether the specific surveillance is lawful depends on the national court’s application of the Directive’s substantive conditions, including legitimate-interest and proportionality limits.


Ryneš v. Úřad pro ochranu osobních údajů, Case C-212/13 (C.J.E.U. 2014)