The Flemish Supervisory Commission (VTC) has expressed critical concerns about the use of ANPR cameras (Automatic Number Plate Recognition) by public authorities. These camera’s not only capture license plates but can also record images of vehicle occupants and information such as the location and time a vehicle is detected. While the technology can aid in addressing traffic issues (and crime), the VTC warns of significant risks to citizen’s rights and freedoms. A key concern is function creep, a growing issue highlighted by the VTC, where technology is repurposed for broader, often unintended applications.

Guidelines and warnings

In 2023, the VTC published guidelines on the use of ANPR cameras. However, complaints received in 2024 revealed shortcomings, leading to a new directive in October 2024, which also serves as a warning. The message is clear: local governments must comply with regulations, or the VTC may suspend the use of these cameras due to privacy violations.

A major criticism of the VTC is that municipalities often implement the technology before defining clear objectives or establishing a legal basis. The scope of applications is then gradually expanded without assessing legitimacy or proportionality. This practice can lead to the systematic monitoring, tracking, and profiling of citizens.

The VTC calls for greater consideration of alternatives, such as physical traffic-slowing measures, awareness campaigns, or targeted controls without the use of cameras. If ANPR cameras are deployed, the following, not yet consistently applied, protective measures should be standard :

• Blurring images when no offense is detected;
• Anonymising data as soon as it is no longer needed;
• Strict data retention policies to prevent misuse.

According to the VTC, local governments often lack sufficient understanding of what must be considered before installing (ANPR) cameras. A comprehensive Data Protection Impact Assessment (DPIA) is essential to analyze risks, including:

• Excessive monitoring of citizens;
• Error margins in ANPR technology;
• The use of permanent blacklists and whitelists and their impact on privacy rights.

The VTC emphasises that communication about camera use must become more transparent and consistent. Currently, the stated purposes and applications can vary depending on which authority—such as a municipality or police department—answers a citizen’s inquiry. This inconsistency creates confusion and undermines public trust. For example, the police might attribute one purpose to a specific camera, while the municipality communicates a different one. Streamlining these explanations is essential to restore clarity and confidence.

The VTC also highlights that financial motives, such as generating additional revenue from fines, cannot constitute a legitimate reason for deploying cameras, even though such motives have been cited by authorities in the past.

The debate surrounding ANPR cameras is not just legal but also political. How far are we willing to go in using technologies that deeply impact citizens' privacy? The VTC calls for a balanced approach: deploy technology only when necessary and ensure robust protection of citizens’ rights.

It now remains to be seen whether this guideline and warning will be acted upon.