Are residents allowed to install smart doorbell equipped with recording function
The Enquiry
A property management company reported that a resident had installed a smart doorbell equipped with recording function, which might capture activities of individuals in public area. The property management company would like to know whether the resident’s act contravened the requirements under the Ordinance.
Our Response
The Ordinance is a piece of technology-neutral legislation, it does not prohibit any individuals or organisations from installing and using CCTV or other similar surveillance devices capable of capturing images of individuals (collectively referred to as CCTV). Generally speaking, if the relevant devices are equipped with recording function that can capture and store images and/or videos of other individuals for identification purposes, this may constitute the collection of personal data. Under this circumstance, the data user is obliged to comply with the Ordinance and the six Data Protection Principles (DPPs) of Schedule 1 thereof.
The operator may make reference to the “Guidance on the Use of CCTV Surveillance” issued by the PCPD, which provides recommendations to data users on the responsible use of CCTV in compliance with the requirements under the Ordinance. Besides, the PCPD has issued “Tips on the Use of CCTV Surveillance” to provide some practical tips to data users on the responsible use of CCTV, including:-
(Uploaded in February 2026)