Licence plate reading cameras at the condominium gate

Cameras that automatically read licence plates at the condominium gate allow the barrier to open for authorised vehicles and record entries. They are useful tools for security and access control, but they process personal data more intrusively than a simple camera: a plate can be linked to a person, and its systematic reading builds a history of movements. For this reason their installation requires particular attention to the GDPR principle of proportionality.

Why a licence plate is personal data

A vehicle's plate makes it possible, through public registers, to identify the owner. Recording it automatically and systematically therefore means processing personal data and, potentially, tracking the movements of owners, family members and visitors. Filming the gate area in general is one thing; extracting, storing and indexing plates is quite another: this last operation is far more invasive and must be justified solidly.

The principle of proportionality and minimisation

Article 5 of the GDPR requires processing only data that is adequate, relevant and limited to what is necessary for the purpose. Before installing a plate-reading system, one must ask whether the goal, typically security and access management, could not be achieved by less invasive means, such as a remote control, a badge or an intercom. If a lighter solution suffices, automatic plate reading becomes disproportionate and therefore unlawful.

The data protection impact assessment

When processing presents a high risk to the rights of data subjects, Article 35 of the GDPR requires a data protection impact assessment. An access-monitoring system that reads and stores plates typically falls among the processing operations that deserve this preliminary analysis. The assessment documents purposes, risks, mitigation measures and retention times, and provides proof of the controller's accountability in the event of an inspection.

The assembly's role

The installation of a video surveillance system on the common parts is decided by the owners' meeting with the majorities set by the Italian Civil Code. A plate-reading system, being a technological installation that affects the common property and the owners' sphere, cannot be decided by the manager alone: a resolution is needed to define its purposes and management. A resolution, however, does not cure any excesses: even a choice approved by the assembly must respect the limits of data protection law.

• Check whether the goal can be met by less invasive means.
• Carry out the impact assessment when the risk is high.
• Resolve in the assembly the purposes and management rules of the system.
• Prepare a notice and signs indicating that plates are read.
• Set short retention times with automatic deletion.

Notice, signs and retention times

As with any video surveillance, signs are needed to warn people before they enter the filmed area, together with a full notice available on request. With plate reading these documents must make clear that the system extracts and stores the plate number, for what purpose and for how long. Retention must be limited to the period strictly necessary to achieve the goal, with automatic deletion on expiry: keeping a prolonged history of transits is an excess that is hard to justify.

Who may access the data

Access to the images and plate data must be restricted to authorised persons only, typically the manager or an appointee, with individual credentials. Individual owners have no general right to consult others' transits: they might obtain images concerning themselves or those useful in the event of a specific incident, but not free monitoring of the neighbourhood. Profiling access to the system is itself a security measure required by the GDPR.

The risk of misuse

The greatest danger of these systems is a slide towards generalised control: knowing who comes and goes, at what time, in which vehicle. A system born for security can turn into a tool for surveillance over the private lives of owners, and this the law does not allow. The golden rule is to keep the system anchored to the stated purpose alone, without adding unnecessary tracking functions.

Documenting the impact assessment, the resolution, the notice and retention times in a single orderly archive reduces the risk of disputes: with AmministraPro the manager keeps the condominium's documents, communications and privacy obligations together. The features are described on the features page and the plans on the pricing page.