Drone exam · Privacy and data protection

A client instructs a pilot to film every person entering a site for 'security evidence.' Can the pilot assume the client alone is responsible for privacy compliance?

Answer

No. The parties should identify their respective roles and responsibilities before the operation. Following a client's instruction does not automatically remove the operator's data protection duties.

Explanation

Depending on the arrangement, a party may act as controller, processor, or joint controller. The operational contract should not be mistaken for the legal analysis.