Icelandic National Police – Dismissed (Iceland, 2021)

On 15 September 2018, the DPA received a complaint about the three cases of processing of personal data by the police in the capital area using audio and video recording equipment in a police car. The complainant complained about three separate incidents on 2017, 2018 and 2018, all of which concerned alleged audio and video recordings in police cars after the complainant was forced to get into the cars. In all cases, the complainant argued that the audio and video recordings made in the police cars were illegal and that he was not informed that the recordings would take place until long after his conversation with the police officers in each case. The police answered that recording equipment in police cars, so-called eyewitness, and body cameras, fall under the category of electronic monitoring within the meaning of the Privacy Act. Authorizations for the police to conduct electronic surveillance are based on the general rules of Act no. 90/2018 on personal protection and processing of personal information and Act no. 75/2019 on the processing of personal information for law enforcement purposes and rules set according to them. According to the police, in the first incident, the recording was only limited to what happened in front of the police car, and not when the complainant had entered the police car. The recording is silent but it is clearly reported that the complainant had been informed that a recording of audio and video was in progress. In the second incident, the audio recording was missing and therefore it is not possible to verify what took place between the police officers and the complainant. However, the documents in the case do not state that the complainant was not informed that the recording of the audio and video was in progress. The third incident involved a police car that was not equipped with witness equipment. The DPA held with regard to the first incident that it has been stated in the responses of the police that the recording was sil