Ryneš v. Úřad pro ochranu osobních údajů

Unknown assailants attacked the Czechoslovakian home of František Ryneš (defendant) and his family for several years, frequently breaking windows. To try to protect his family and home from these assaults, Ryneš installed a video camera on part of his house. The video camera recorded Ryneš’s front door and an area in front of the house, including a neighbor’s door and a public path. The recorded data was stored directly on a hard drive and accessible only to Ryneš. Ryneš did not post any notices or otherwise notify the public about the video camera. When the video camera captured images of two suspects breaking a window on the home, Ryneš gave the recording to the police, who used it to prosecute the suspects. One of the suspects complained to the Czech Office for Personal Data Protection (plaintiff), claiming that Ryneš had collected the suspect’s personal data in violation of the European Union’s Directive 95/46/EC (the directive). The directive prohibited automatically collecting and processing someone’s personal data without the subject’s notice or consent. Videotaping was a way to automatically collect and process information. However, the directive had an exception that allowed the automatic processing of someone’s personal data if the processing occurred in the course of a purely personal or household activity. The European Union Court of Justice was asked to provide guidance about whether a videotape made for purely personal reasons that also captured personal data from a public space qualified for the purely-personal-or-household-activity exception in the directive.