Clinical photographs and hospital CCTV

Overview

The NPC treated clinical photographs as sensitive health information and CCTV images of identifiable people as personal information. Clinical images taken for medical treatment may be processed under the treatment ground if adequate protection is ensured. The opinion recommends specific policies for photographs and CCTV.

Practice implications

Parao Law practice guidance

For physicians

Use an approved clinical-image workflow. Define when images may be taken, who may access them and how they are transmitted. Keep treatment images out of personal messaging or social accounts. Tell patients where CCTV operates and route footage requests through the privacy team.

For lawyers

Distinguish treatment images from secondary uses such as teaching or publication, which require their own lawful basis. Review access and transfer controls, surveillance notices and requests for footage that also identifies other people; masking may be appropriate.