CJEU, judgment of 11 December 2014, C-212/13, Ryneš
Private video surveillance and the household exemption: surveillance of publicly accessible areas falls within the scope of data protection law.
1 Overview
In this decision, the Court clarified the reach of the so-called household exemption. A private individual had installed a video camera on his house which also captured part of the public street.
Reference: CJEU, judgment of 11 December 2014, C-212/13, Ryneš
2 Household exemption under Article 2(2)(c) GDPR
The exemption for purely personal or household activity is to be construed narrowly. As soon as the video surveillance captures the public space, even if only in part, there is no longer a purely personal activity; the GDPR is applicable.
3 Significance for Article 6(1)(f) GDPR
The decision is formative for the assessment of private video surveillance under data protection law. Private cameras that capture publicly accessible spaces require a legal basis, as a rule the balancing of interests under Article 6(1)(f) GDPR.
About the author
About the author
This article was written by Dr. Thomas Helbing, specialist lawyer for IT law in Munich.
Since 2020 and continuously through today (2026), Handelsblatt has recognized Dr. Helbing as one of "Germany's Best Lawyers" in IT law and data protection law.
According to Kanzleimonitor.de (2024 to 2026 editions), he ranks among the leading lawyers for data protection and IT law and is listed among the top 100 lawyers in Germany (2024/25). Kanzleimonitor is considered a particularly meaningful market study because it is based exclusively on personal recommendations from in-house counsel.
Dr. Helbing has many years of advisory experience in data protection and IT law and advises clients of all sizes, from startups through fast-growing SaaS companies and unicorns to international corporate groups.
His professional background covers the full spectrum of IT and technology law practice. He began his career at a major international law firm, then gained in-house experience at a DAX-listed company, and is himself an entrepreneur and founder of several digital ventures. He also has hands-on programming experience, which allows him to understand technical systems, software architectures and digital business models not only from a legal perspective but also from a technical one.
For many years, his clients have included technology companies and SaaS providers, leading German research institutions and a systemically important German bank. His advisory focus lies in particular on GDPR compliance, the data economy, SaaS, AI regulation and IT contract law.
CJEU, judgment of 8 December 2022, C-180/21, Inspectoratul General pentru Imigrări
Processing of personal data by public authorities in judicial proceedings; delimitation between Article 6(1)(c) and (e) GDPR and in relation to Directive (EU) 2016/680.
German Federal Administrative Court (BVerwG), judgment of 27 September 2018, 7 C 5/17
Requirements for national legal bases for data processing in the public sector; limits of general catch-all clauses.