The following guidelines relate to the recording of video conferences (for example, using the recording function in Teams) including images and/or voices.
The recording of video conferences includes voices, images (still and/or moving images) and names of people – information which constitutes personal data. The recording, storage, display and handling of such data in connection with video conferencing constitute personal data processing whereupon compliance with the rules of the General Data Protection Regulation (GDPR) and LKAB’s Guidelines for Personal Data Processing must be observed.
Video conferencing containing personal data (e.g. voices, images and names) may be recorded, stored and displayed for the following purposes:
- To allow for those at LKAB who cannot attend a video conference to gain access to information from the conference at a later date. Once the relevant person(s) has/have seen/accessed the recorded video conference, it must be deleted – however, no later than within twelve months from the date of recording.
- To be used for educational purposes. Once the training has been completed, the video recording must be deleted – however, no later than twelve months from the date of recording (unless all course participants have agreed in writing to an extended storage period).
- To document circumstances/situations where the recording of video conferences is essential for LKAB to deal with matters of material importance to the company. Such video conference recordings shall be deleted once the purpose of the recording no longer exists. It is the responsibility of the Department Manager or equivalent to decide whether a video conference should be recorded for the purpose intended.
Please remember that the recording of a video conference is sometimes prohibited due to confidentiality. The person responsible for recording a video conference must always attend the video conference him/herself. The persons attending a video conference must always be informed about the recording before it begins. Hence, it is not allowed to record a video conference without first having informed those present about the recording. If there is any uncertainty about whether or not a recording, etc., ought to take place, the immediate manager should be contacted for advice on the matter.
It is therefore required that anyone subject to such processing of personal data that may occur in connection with a video conference (for example, through recording, storage, etc.) shall be adequately informed in advance.
The person inviting others to attend a video conference (the conference organiser) is normally the only person authorised to record and share recordings from the conference. As Personal Data Controller, it is the responsibility of LKAB to ensure that any personal data disclosed during a video conference is processed in accordance with current laws and regulations (including GDPR).
The conference organiser shall ensure compliance with the requirements of GDPR as well as LKAB’s Guidelines for Personal Data Processing. This includes making certain that recordings of video conferences are only shared with persons authorised to receive such recordings, that recordings are made for a legitimate purpose and that processing of personal data is carried out in the prescribed time.
Only the video conference organiser can start a recording provided that all conference attendees have been informed about the recording and the purpose of the same. It is the right of every conference attendee to decide whether or not to appear on camera by, for example, enabling/disabling the camera.
Video conference recordings should not be shared with other organisations or persons outside of LKAB, unless for specific legitimate reasons (e.g. the existence of a Personal Data Processing Agreement with a supplier).
Legitimate interest constitutes the lawful basis for processing personal data obtained in connection with a video conference. LKAB believes that the interest in processing personal data disclosed during a video conference, for the purposes stated above (e.g. images and voices), outweighs the privacy interests of individual conference attendees.
To learn more about LKAB’s personal data processing, the rights of the identifiable person and about the data controller organisation (including contact details), etc., go to our page about processing of personal data.