Videoüberwachung des öffentlichen Straßenraums im Stadtgebiet Frankfurt am Main – ein Schriftwechsel mit dem hessischen Datenschutzbeauftragten Prof. Dr. Ronellenfitsch
In einem Schreiben vom 23.06.2019 an den Hessischen Datenschutzbeauftragten Prof. Dr. Ronellenfitsch hat die Bürgerrechtsgruppe dieDatenschützer Rhein Main nach der weiteren Bearbeitung ihrer Beschwerde vom 26.05.2014 gefragt. Damals hatte die Gruppe dem Hessischen Datenschutzbeauftragten eine Liste mit 369 Standorten von Videoüberwachungsanlagen (insgesamt ca. 820 einzelne Kameras) übermittelt, mit denen Straßen und Plätze in Frankfurt überwacht werden. Mehr als fünf Jahre danach ist festzustellen:
Nach den der Gruppe bekannten Rückmeldungen des Hessischen Datenschutzbeauftragten wurden bislang 142 der 369 Standorte von Überwachungskameras abschließend geprüft. Dies entspricht 38,5 % aller Anlagen. Die bislang letzte Rückmeldung ging ein am 10.09.2018. Seitdem herrscht „Funkstille“.
Am 16.07.2019 ging das Antwortschreiben des Hessischen Datenschutzbeauftragten bei der Bürgerrechtsgruppe dieDatenschützer Rhein Main ein. Er nennt darin höhere Zahlen (161 statt 142 abschließend bearbeitete Anfragen zu Videoüberwachungsanlagen, die von privaten Personen und Einrichtungen betrieben werden) sowie noch nicht beantwortete Anfragen zu Videoüberwachungsanlagen, die von öffentlichen Einrichtungen auf der Basis des Hessischen Sicherheits- und Ordnungsgesetzes (HSOG) betrieben werden.
Im vorletzten Absatz seines dreiseitigen Schreibens erklärt Herr Prof. Dr. Ronellenfitsch:
Diese Passage muss auf Unverständnis und Widerspruch stoßen. Denn im Schreiben vom 23.06.2019 hat die Bürgerrechtsgruppe dieDatenschützer Rhein Main ausdrücklich festgestellt, dass sie „nicht am guten Willen Ihrer Mitarbeiter*innen (zweifelt), hier sorgfältig zu arbeiten und Verstöße zu ahnden. Zweifel sind aber mehr als angebracht, ob Ihrer Behörde hinreichende Ressourcen zur Verfügung stehen, um den gesetzlichen Aufgaben nachkommen zu können. Auch nach Inkrafttreten der Europäischen Datenschutzgrundverordnung (DSGVO) am 23.05.2018 – sie löste bei allen Datenschutz-Aufsichtsbehörden eine Vervielfachung der Anfragen und Beschwerden aus – hat sich nichts getan. Sie schweigen sich dazu öffentlich aus.Das unterscheidet Sie nachteilig von vielen Ihrer Amtskolleg*innen im Bund und den anderen Bundesländern.“
Und zu dieser Thematik schweigt sich Prof. Dr. Ronellenfitsch auch in seinem Antwortschreiben von 16.07.2019 weitgehend aus. Er teilt dazu lediglich in allgemeinster Form mit: „Den bisher vom Hessischen Landtag bewilligten Personalzuwachs in meinem Hause musste ich – nicht zuletzt wegen sich aus der DSGVO ergebenden Konsequenzen – bisher z. B. In den Aufbau einer Stabsstelle Europa, in das hiesige Justiziariat und andere Bereiche kanalisieren.“
Zum materiellen Ergebnis bei der Bearbeitung der Eingabe der Bürgerrechtsgruppe dieDatenschützer Rhein Main vom 26.05.2014 ist festzustellen, dass vom Hessischen Datenschutzbeauftragten mitgeteilt wurde, dass
-
es sich bei 13 (9,2 %) aller überprüften Anlagen um Kameraattrappen handeln soll, die zwar auch einen Überwachungsdruck auslösen, aber nicht der Aufsicht der Datenschutzaufsichtsbehörden unterliegen;
-
bei 24 (16,9 %) aller überprüften Anlagen die Kamerabetreiber die Kameras datenschutzkonform neu ausgerichtet haben, so dass öffentlicher Raum nicht mehr im Blickfeld der Kameras ist;
-
bei 29 (20,4 %) aller überprüften Anlagen die Kamerabetreiber die Kameras nach Eingang der Beschwerde ersatzlos abgebaut haben und
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in 76 der insgesamt 142 Fälle (53,5 %) die Kameraausrichtung nach den Bewertungen der Behörde den gesetzlichen Erfordernissen entspricht.
Die Bürgerrechtsgruppe dieDatenschützer Rhein Main bewertet dieses Ergebnis im Grundzug positiv, da es zeigt, dass Beschwerden gegen Videoüberwachung des öffentlichen Raums durch private Kamerabetreiber häufig rechtswidrig ist und erfolgreich eingedämmt werden kann.
Zwei anschließende Hinweise:
- Unter dem Titel “Videoüberwachung – wie kann ich mich dagegen zur Wehr setzen?“ hat die Bürgerrechtsgruppe dieDatenschützer Rhein Main Informationen zu Rechtsgrundlagen und Verfahrensregeln bei Videoüberwachung und Tipps für die Gegenwehr veröffentlicht.
- Mit dem sogenannten Videoüberwachungsverbesserungsgesetz hatte der Bundestag 2016 den Weg für eine Ausweitung der Videoüberwachung durch private Kamerabetreiber geschaffen. Die Möglichkeit, öffentliche und frei zugängliche Bereiche (Sport-, Versammlungs- und Vergnügungsstätten, Einkaufszentren, Parkplätze, Einrichtungen und Fahrzeuge des öffentlichen Personenverkehrs) durch private Kamerabetreiber überwachen zu lassen, wurde stark ausgebaut. Das Bundesverwaltungsgericht hat in einer kürzlich veröffentlichten Entscheidung vom 27.03.2019 deutlich gemacht, dass die Regelung, die von CDU/CSU und SPD im Bundestag beschlossen wurde, europarechtswidrig ist. Laut Bundesverwaltungsgericht ist die Videoüberwachung durch private Stellen ausschließlich am europäischen Datenschutzrecht (DSGVO) zu messen ist. Nach Auffassung des Bundesverwaltungsgerichts regelt die Europäische Datenschutzgrundverordnung (DSGVO) die Videoüberwachung durch Private abschließend. Das Gericht stellt unmissverständlich fest:
- “Eine Privatperson kann sich nicht selbst zum Sachwalter des öffentlichen Interesses erklären. Insbesondere ist sie nicht neben oder gar anstelle der Ordnungsbehörden zum Schutz der öffentlichen Sicherheit berufen. Beim Schutz individueller Rechtsgüter, seien es ihre eigenen oder diejenigen Dritter, verfolgt sie keine öffentlichen, sondern private Interessen…” (Randnummer 46 der Urteilsbegründung).
- “Aufgrund dessen ist kein Raum für eine künftige Anwendung des § 4 Abs. 1 Satz 1 des… Bundesdatenschutzgesetzes… Diese sind an Art. 6 Abs. 1 Unterabs. 1 Buchst. f DSGVO zu messen. Danach muss die Verarbeitung zur Wahrung der berechtigten Interessen des Verantwortlichen oder eines Dritten erforderlich sein, sofern nicht die Interessen oder Grundrechte und Grundfreiheiten der betroffenen Person, die den Schutz personenbezogener Daten erfordern, überwiegen…” (Randnummer 47 der Urteilsbegründung).
Frankfurter Gemeine Zeitung » Blog Archiv » Videoüberwachung
des öffentlichen Straßenraums im Stadtgebiet Frankfurt am Main –
ein Schriftwechsel mit dem hessischen Datenschutzbeauftragten Prof.
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