Drone exam · Privacy and data protection

A roof survey records a person too small to recognise by face, but their distinctive uniform, vehicle registration, and exact work location are visible. Could the recording still contain personal data?

Answer

Yes. Personal data is not limited to a clear face. If the information can identify or single out a person directly or indirectly, the recording may contain personal data.

Explanation

Several details can combine to identify someone even when none is decisive alone. Drone operators should assess the whole dataset, including location, time, vehicles, uniforms, and other context.