National Privacy Commission issues guidelines on the processing of personal data collected using body-worn cameras

The National Privacy Commission (NPC) released NPC Circular No. 2025-01, establishing guidelines on the processing of personal data collected using body-worn cameras and similar recording devices to establish protocols for the protection of data subjects’ personal data and their data privacy rights. The Circular became effective on 10 June 2025. 

 The Circular outlines protocols on protecting data subjects’ personal data, emphasizing lawful basis for processing of personal data, security measures, the importance of secure storage, safekeeping, access control, and overall management of audio-visual recordings and metadata generated through these devices. 

Privacy Commissioner Atty. John Henry Naga emphasized the significance of the Circular, “With the growing use of body-worn cameras across law enforcement, private security, and even digital content creation, we are entering a new era where the boundary between public safety, personal expression, and individual privacy is increasingly complex. NPC Circular No. 2025-01 reflects our commitment to ensuring that technologies meant to enhance transparency and accountability do not come at the cost of unwarranted surveillance or intrusion of privacy.” 

 

Requirements for law enforcement officers and security guards, vloggers 

The Circular sets out requirements for law enforcement and security, as well as vloggers using body-worn cameras and other recording devices.  

For law enforcement agencies, the Circular reinforces the requirement to observe transparent, fair, and lawful use of body-worn cameras, especially in sensitive operations such as the execution of warrants. Agencies must ensure proper authorization, clear retention policies, and mechanisms for public access requests and complaints. 

For vloggers and digital content creators, the Circular clarifies that recording individuals in public or private settings, especially when these recordings are uploaded, streamed, or monetized, constitutes personal data processing. As such, content creators must uphold the Data Privacy Act of 2012, ensuring that personal data processing activities are done in a fair and lawful manner and affected data subjects are allowed to exercise their rights. This includes, among others, providing adequate information to data subjects prior to any recording activity, having appropriate privacy notices on its platforms, masking images of data subjects as needed, and being responsive to takedown or privacy requests from featured individuals. 

The NPC urges all stakeholders, including law enforcement agencies, private security firms, and content creators, to familiarize themselves and comply with the provisions of NPC Circular No. 2025-01. 

 

For more information and to access the full circular, please visit:

NPC Circular No. 2025-01 - Guidelines on the Processing of Personal Data Collected Using Body-Worn Cameras

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