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Body-worn cameras - handling of personal data

On all routes operated by SJ AB or one of SJ AB's subsidiaries ("SJ" or "we"), our employees may be equipped with body-worn cameras. The body-worn cameras are worn on the uniform and record moving pictures and sound upon manual activation.

The purpose is for the cameras to contribute to increased safety and security of passengers and employees. The cameras are used for crime prevention purposes, as the camera can have a calming effect, and the recorded material may be used as evidence in connection with any crime.

The camera continuously records moving pictures and sound. The cameras have a so-called circular memory, which means that all material older than 15 seconds is automatically erased. When the camera is activated manually by an SJ employee, for example, in the event of a threatening situation, everything recorded is saved until the camera is switched off, as well as the 15 seconds recorded just before activation.

Consequently, when you travel with a train operated by SJ, we may collect the following personal data related to you:

  • Moving pictures
  • Sound
  • Location information, i.e. where the material was recorded.

SJ AB is the controller of personal data for the processing of this personal data.

In order for the film recording to be considered personal data, the person in the film must be identifiable.

 

Legal basis

Because the body-worn cameras are controlled manually by the employee wearing the camera, the Camera Surveillance Act does not apply. However, SJ always processes personal data in accordance with the requirements of all other data protection legislation. All processing of personal data must have a legal basis in accordance with the General Data Protection Regulation

We process your personal data (collect, store, review and share) with reference to SJ’s legitimate interests. In light of the applicable restrictions and security measures, we deem that the potential of SJ to reduce the risk of SJ employees and passengers being exposed to crime and the ability of SJ to document and review recorded material to provide evidence to the police when reporting a crime to outweigh the data subject's interest in protecting their privacy.

SJ also has a legal obligation to share personal data with the police and other authorities in certain cases, for example when the police have initiated a preliminary investigation.

Storage and purging

The film material recorded after manual activation is stored in an encrypted format on protected devices and is deleted automatically after 5 days.

Material that will constitute evidence is stored for up to 30 days. After transfer to the police, the material is deleted immediately.

If you have been a victim of a crime

If you have been the victim of a crime on board our trains that you believe has been film recorded, you should immediately file a police report so that the police can quickly request recorded material. Otherwise, there is a risk that the material will be deleted in accordance with the above.

Technical and organisational security measures

SJ has taken several measures to minimise the exposure of and protection of personal data that is processed as a result of SJ's use of body-worn cameras by:

  • Minimising film recording by having the employees only activate the camera in situations that are perceived, for example, as being threatening.
  • Minimising storage of recorded material through automated deletion and applying short time intervals for such material.
  • Protecting recorded material with technical measures and by strictly restricting access to a few persons with special knowledge and authorisation.
  • Providing training and clear instructions for anyone handling cameras, software and recorded material.

Sharing of personal data

Under the conditions set forth above, personal data may be shared with, among others, the police or other authorities.

In exceptional cases, personal data may also be processed by the suppliers of SJ's maintenance and technical support for the camera and its software. The processors of personal data engaged by SJ may only process personal data in accordance with the limited purposes and specific instructions which SJ provides, and do not have any common access to the recorded material.

Transference of personal data outside the EU/EEA

All of SJ's personal data processing related to body-worn cameras takes place within the EU/EEA.

Dina rättigheter

You have certain rights under the data protection legislation, such as the right of access to your personal data, deletion and data portability. You can read more about how to exercise your rights at sj.se/dataprotection

If you wish to exercise your rights, you are welcome to contact SJ by e-mail at dataskydd@sj.se

Questions and comments

SJ has appointed a Data Protection Officer (DPO) to ensure that SJ processes your personal data in a lawful, correct and transparent manner. If you have a matter you would like to address to our Data Protection Officer, please contact us at dataskydd@sj.se and enter "DPO" in the subject line of your message.

If you believe that our processing of your personal data is not in accordance with the data protection legislation, please contact us as above. You are also entitled to make a complaint to the Swedish Authority for Privacy Protection.

Updates of this information

This information may be updated. The latest version is always published here.

Last updated 20 October 2021.