Court of Justice 1 August 2025, C-422/24 (Opinion of Advocate General Medina delivered on 1 August 2025.)

Also known as

In Case C-422/24, Advocate General Medina opines that Article 13 of Regulation (EU) 2016/679 (GDPR), rather than Article 14, governs the controller's obligation to provide information where personal data are collected by means of body cameras worn by ticket inspectors employed by a public transport company, on the ground that such collection constitutes direct collection from the data subject within the meaning of Article 13, the decisive criterion being the source of the data rather than any active participation or awareness on the part of the data subject. The AG reasons that the data subject's physical presence within the camera's field of capture makes that person the source of the data, thereby triggering the obligation to provide information at the time of collection, and that the layered approach to information provision recognised for video surveillance is equally practicable for body cameras, rendering inapplicable the disproportionate-effort exception under Article 14(5)(b). Accordingly, the AG proposes that the Court answer that Article 13 applies and Article 14 does not apply in the circumstances described.AI