Digital health surveillance: the new official guide (cross-border guide)

Context

In brief

• New guide on digital surveillance
• Published by FDPIC and privatim
• Hospital monitoring under scrutiny
• Protection of data for cared-for individuals

Key facts

• Date: September 16, 2026
• Authorities: FDPIC and privatim
• Sector: Hospitals and social-medical facilities
• Technologies: Cameras, infrared sensors, and radar

The use of cameras, infrared sensors, or radar to monitor cared-for individuals in hospitals or similar facilities is becoming increasingly relevant in today's healthcare landscape. On September 16, 2026, the FDPIC and privatim published an official guide aimed at illustrating fundamental data protection issues and raising awareness among facilities intending to use this type of technological surveillance. Digital surveillance of cared-for individuals in hospitals, social-medical facilities, and other care institutions can take various operational forms. It may involve direct surveillance, which provides real-time image transmission to healthcare staff. Alternatively, it can be indirect surveillance, based on converting images into pictograms that indicate the real-time position of the person within the room. There is also a situational form, characterized by sending a signal or pictogram to the staff only in the event of a predefined occurrence, such as a fall from a bed. Whether based on optical cameras, infrared sensors, or radar, this form of surveillance involves high-intensity data processing. Such monitoring directly intervenes in the private, and sometimes even intimate, sphere of the cared-for individuals, who are often in situations of particular vulnerability.

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Operational details

The purposes for which digital surveillance is implemented must be strictly defined and oriented exclusively toward the interest of the care recipient, such as improving their overall safety. Purely logistical reasons, such as simply verifying that staff have made a bed, are not considered sufficient to justify such invasive data processing. Furthermore, digital surveillance must always be proportional to the stated purpose and must represent a subsidiary measure compared to other less invasive solutions. If the primary objective is to prevent nighttime falls, alternative measures, such as the use of bed rails, must be considered as a priority. The technological solution adopted must have the least possible impact on the life of the care recipient. Consequently, indirect or situational surveillance, meaning activated only in the event of an incident, should be favored over continuous real-time monitoring, sending staff only the strictly necessary data and preserving privacy outside of critical situations.

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Key points

Operations and controls for healthcare facilities

Healthcare institutions that intend to introduce or revise monitoring systems based on cameras, infrared sensors, or radars must establish a structured internal roadmap. The first operational step consists of drafting formal documentation that justifies the adoption of the technology in terms of necessity and proportionality. This preliminary phase must exclude the use of purely logistical or management motivations. Subsequently, an in-depth analysis of the risks related to privacy and the protection of the personal data of the people being cared for must be carried out. This analysis must consider the possibility of opting for less invasive solutions, such as situational surveillance systems or indirect surveillance via pictograms, which minimize the transmission of detailed images to healthcare personnel. Regulatory compliance also requires the verification of the reference legal framework, clearly distinguishing between the position of public facilities, bound by the principle of legality and cantonal law, and that of private clinics, which must strictly adhere to the dictates of the Federal Act on Data Protection.

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