The Commission for Personal Data Protection ('CPDP') issued, on 19 October 2022, a statement on the use of digital doorbells and peepholes, addressing how they affect privacy and data protection. In particular, the CPDP explained that digital doorbells and peepholes are built into the door or wall of a property and are equipped with an external camera that allows monitoring of the space in front of the door. More in detail, the CPDP noted that certain models allow a live transmission to a mobile device, in the same manner as traditional peepholes, while others allow footage to be obtained only after approaching a certain distance from the owner's door, which serves to protect against trespassing.

Further to the above, the CPDP outlined that digital bells and peepholes must be used to replace traditional peepholes to provide greater security for their users, highlighting that such devices cannot be used as a video surveillance system, affecting other property owners and visitors in the building. Specifically, the CPDP detailed that there is no processing of personal data and thus the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR') does not apply. In this regard, the CPDP explained that the former applies only when digital doorbells and peepholes use functions like traditional ones and the person standing in front of the doorbell camera is visualised and recognised after ringing or is at a distance close enough to the doorbell and the front door and no recordings are made and saved.

You can read the press release, only available in Bulgarian, here.