Reykjavík Health Inspectorate – Dismissed (Iceland, 2021)

The DPA received the complaint that representatives of the Reykjavík Health Inspectorate (HER) entered the complainant's private property without notifying him and took photographs of his property and belongings without permission. He also argues that during the visit, HER employees did not maintain proportionality and violated his privacy. HER explained that according to Icelandic laws on hygiene and pollution prevention, landowners are obliged to keep their properties clean and tidy and to properly arrange waste treatment. The Inspectorate received a complaint that there was an accumulation of car wrecks and other waste on the complainant's yard. Hence, HER decided to take 23 photographs of the scene as evidence, as there was a certain risk of a pollution accident. Was the Reykjavík Health Inspectorate (HER) allowed to process the complainant's data? The DPA confirmed that HER works on behalf of the Reykjavík City Health Committee and is responsible for enforcing the Icelandic laws on hygiene and pollution prevention. The processing of personal data covered by the complaint relied on an authorization according to specific provisions of the Icelandic law that allow HER workers to take photos while performing their job.