By Alex Liu

Hong Kong, 22 December 2025: Complaints about video surveillance are on the rise as more individuals and companies in Hong Kong install CCTV systems on their premises. The Office of the Privacy Commissioner for Personal Data (PCPD) has received some 200 complaints this year – with 80% of these relating to disputes between neighbours – while also fielding around 1,660 inquiries on the same topic.

In one incident reported by media outlets, the watchdog sent a warning letter to a 24-hour fitness chain which had mispositioned a CCTV camera to face the missing door of a men’s bathroom at its branch in Ma On Shan. The investigation found that the camera had not been activated and it was subsequently removed.

The increasing number of complaints has caused the PCPD to publish two leaflets – Guidance on the Use of CCTV Surveillance and Tips on the Use of CCTV Surveillance – to assist system operators and the public, thus promoting the protection of individual data and underscoring the need for compliance with the Personal Data (Privacy) Ordinance.

Together, the leaflets provide an overview of the considerations for deploying CCTV systems, including lawful use, avoiding unfair surveillance, informing the public, deleting footage and implementing adequate security measures.

Traditional CCTV systems have existed for decades, of course, but major advances in technology mean they are now more powerful, sophisticated and – potentially – intrusive than ever, with artificial intelligence pushing the boundaries. Facial recognition technology, for example, is widely available. Such systems are increasingly being used by property management companies, but the PCPD points out that less intrusive solutions – such as more frequent security patrols and enhanced resident engagement – can be considered first.

Camera positioning is also important as it should avoid capturing the interiors of private residences. Further, as evidenced by the fitness chain example, placing cameras in places where individuals have a reasonable expectation of privacy is to be avoided, not least because it could lead to potential offences such as voyeurism.

CCTV systems are not the only privacy concern for the PCPD, however, with in-vehicle cameras and those operated by drones also warranting attention. In the first instance, it should be noted that our government plans to complete the installation of in-vehicle cameras in all taxis by the end of 2026 to improve the quality of services and protect the interests of both drivers and passengers. As for drones, the authorities are committed to building a low-altitude economy ecosystem and promoting Hong Kong as an Asia-Pacific hub for innovative low-altitude applications.

Hence, the PCPD has published two further leaflets: Guidance on the Use of Video Cameras on Drones and Vehicles outlines the privacy risks associated with such devices and offers advice on avoiding excessive collection of personal data, notifying affected individuals and the security of recorded footage; meanwhile, Responsible Use of Drones and In-Vehicle Cameras summarises the key points to note for data users.

In-vehicle cameras often record both video and audio data, capturing the faces and conversations of drivers and passengers. Unauthorised use of recordings, especially if they go viral, could expose individuals to doxxing, harassment or cyberbullying. Drones, in particular, have the capacity for misuse, given that they can capture data from a distance and members of the public are often unaware of their presence.

In conclusion, we should note that as technological advances accelerate and surveillance becomes a part of our everyday lives, there is a need for balance between security and privacy. The PCPD’s guidelines on the use of CCTV, in-vehicle cameras and drones are a welcome assistance tool for the public’s awareness and compliance.

Alex Liu is Managing Partner of BC&C. His key areas of practice include commercial and corporate litigation, investigations by governmental bodies such as the SFC, ICAC and Commercial Crime Bureau, insolvency and debt restructuring, intellectual property and employment matters. He can be contacted at alex@boasecohencollins.com.