More Cameras on the Factory Floor Means More Privacy Risk
Cameras are multiplying inside factories. Smart safety equipment with AI human detection, vision AI quality inspection and AMRs (autonomous mobile robots) are all spreading. A camera may be installed for "safety" or "quality," but once it captures a worker's face or movements, that footage is personal data. Features that analyze behavior, such as fall detection or alerts when someone enters a danger zone, need extra care. Facial recognition that identifies a specific person goes further: it counts as sensitive data (biometric information) under Korean law and requires separate consent.
Some companies install equipment through a support program, then have to stop running it after a labor dispute or complaint. Checking in advance prevents that.
Fixed Cameras: Start With the Legal Basis
A factory interior with controlled access is usually not a "publicly accessible place." So collecting footage there falls under the general rules of Article 15 of the Personal Information Protection Act (PIPA), and you need a legal basis. One option is worker consent. The other is to show that the employer's legitimate interest is clear and outweighs workers' rights (Article 15(1)6). Facility safety, fire prevention and trade secret protection are typical examples. Even then, you must keep the camera's coverage to a minimum and never use the footage for other purposes.
The most common risk is purpose creep. Suppose footage collected for safety is later used to check attendance, rate work speed or support discipline. That use may go beyond the original purpose of collection. Publish the purpose, coverage area, operating hours and retention period on signage and in your privacy policy.
Moving Cameras: AMRs, Robots and Wearables
The amended PIPA, in force since September 15, 2023, added rules for mobile video devices (Article 25-2). To film people with a mobile device in a publicly accessible place for business purposes, one of these must apply:
Filming can be indicated with lights, sounds, signs, written notices or announcements.
AMRs that stay inside the plant are mainly governed by Article 15. Robots that work in yards or shipping areas where outsiders come and go, or that travel onto public roads, need a closer look under Article 25-2. Either way, write these items into the supplier's delivery specification up front:
Don't Miss the Labor-Management Council Consultation
Article 20 of the Act on the Promotion of Workers' Participation and Cooperation lists "installation of worker monitoring equipment in the workplace" as a matter the labor-management council must be consulted on. Workplaces with 30 or more regular employees are required to have a council. It is safest to consult before installation work begins, ideally while the business plan is still being finalized. The minutes should record:
Reducing Risk Through Data Architecture
With edge processing, video is analyzed on site and only events are saved, such as a clip of a few dozen seconds around an alarm. This keeps far less data than streaming raw video to the cloud all the time, so the risk is lower. Many companies set retention at around 30 days. Limit who can access footage and keep access logs.
If a supplier or cloud provider handles the footage, sign a data processing outsourcing agreement (Article 26). If you employ foreign workers, provide notices in their main native languages as well.
A 10-Point Checklist Before You Install
Build these items into the business plan or contract amendment for smart factory or smart safety equipment support programs, so you have less to change later. The consultation may change camera locations or analytics features, and that can mean changing the equipment specification. The sensible order is to finish the consultation first, then lock in the specs.
How KITIM Can Help
KITIM helps design video data processing structures at the application stage of smart factory and safety equipment support programs. We also advise on preparing labor-management consultation materials and internal rules for operating video systems. If you are planning to install cameras, contact the KITIM consulting team before you finalize the equipment specs.