Take-Aways (AI)
  • The Zug High Court ruled that dash­cam recor­dings may be per­mis­si­ble under data pro­tec­tion law after weig­hing up the inte­rests involved.
  • Dash­cam evi­dence was admis­si­ble, as the com­plainant was entit­led to pre­ser­ve evidence.
  • This was trig­ge­red by con­sidera­ble tail­ga­ting by the defen­dant, which crea­ted a con­cre­te risk of rear-end collisions.
  • The inte­rest in pre­ser­ving evi­dence out­weig­hed the per­so­nal rights of the accu­sed; the crossing of the dou­ble safe­ty line is dee­med to have been proven.

The Zug Supe­ri­or Court has – alre­a­dy on May 11, 2017 – ruled (Decis­i­on of May 11, 2017, GVP 2017, 195) that the use of a dash­cam can be per­mis­si­ble under data pro­tec­tion law based on a balan­cing of inte­rests and that evi­dence obtai­ned accor­din­gly can be usable:

[…] in the pre­sent case, it is cru­cial to add that the com­plainant entit­led to pre­ser­ve evi­dence had been the dash­cam, after the defen­dant had hara­s­sed him with his Por­sche in such a wayThe defen­dant was not allo­wed to start or run the car. In agree­ment with the lower court, no ille­ga­li­ty is to be reco­gnized in this, espe­ci­al­ly sin­ce the defen­dant crea­ted the dan­ger of a rear-end col­li­si­on with his dri­ving beha­vi­or, which could have had serious con­se­quen­ces in view of the high speeds (in agree­ment appar­ent­ly with the Fede­ral Data Pro­tec­tion and Infor­ma­ti­on Com­mis­sio­ner, accor­ding to which the under­stan­da­ble inte­rest in having pic­tures available as evi­dence in the event of acci­dents does not con­sti­tu­te an inte­rest that out­weighs the pro­tec­tion of per­so­na­li­ty; cf. OG GD 5/11 p. 2 [Note: cf. here]). In other words has the recor­ding of the crossing of the dou­ble safe­ty line is given a cau­se refe­rence by the first cle­ar­ly more weigh­ty vio­la­ti­onThe­r­e­fo­re, con­tra­ry to the opi­ni­on of the defen­dant, the­re is no unlawful vio­la­ti­on of per­so­na­li­ty rights and thus no pro­hi­bi­ti­on of the use of evi­dence. Under the given cir­cum­stances, the inte­rest of the com­plainant in ope­ra­ting or run­ning the dash­cam to pre­ser­ve evi­dence was to be rated hig­her than that of the defen­dant in moving unob­ser­ved and uncon­trol­led in road traf­fic. Thus, the crossing of the dou­ble safe­ty line is pro­ven (dou­bly, so to speak).