Digital health surveillance: the new official 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.

Common regulatory principles for surveillance

Regardless of the type of surveillance and the specific technology used by the facilities, the principles and rules to be respected remain the same throughout the territory. First and foremost, surveillance must be lawful. Regarding public facilities, such as cantonal hospitals and nursing homes with a public mandate, the principle of legality strictly applies. This means that surveillance must be provided for, more or less directly, by cantonal law. For private facilities, such as clinics without a public mandate, lawfulness fundamentally depends on compliance with the principles enshrined in the Federal Act on Data Protection. The consent of the data subjects, although desirable where possible, is neither necessary nor sufficient to justify surveillance, and this applies to both public and private facilities. Informing the cared-for individual, on the other hand, plays an essential role in the process: every patient must be clearly informed regarding the objective of the surveillance and its specific implications.

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.

Security and Organizational Transparency Requirements

A further central aspect concerns compliance with the principles of privacy by design and data security. This implies the design and adoption of technical solutions that best guarantee the protection and security of the collected information, taking due account of all relevant factors of the operational context. These include effectiveness regarding the pursued purpose, management of associated risks, availability of valid alternatives, as well as the organizational and financial constraints of the institution. When a healthcare facility evaluates the adoption of a digital surveillance system, it is required to follow a rigorous path: precisely define the pursued objectives, fully understand the implications of the chosen solution and its relative configuration options to avoid unnecessary data processing, document all choices made also through dedicated risk analyses, keep technical and organizational documentation constantly updated, regularly evaluate and control the system in use to certify its adequacy over time, and finally adequately train staff to ensure fully compliant and responsible use of such technological tools within the facility.

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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.

The practical implementation phase cannot disregard constant monitoring activity and a targeted training plan aimed at all healthcare workers involved in the use of the devices. Personnel must be trained not only on the correct technical operation of the equipment, but also on the limits imposed by regulations regarding high-intensity data processing. To learn more about aspects related to personnel management, operating costs, and related services available nationwide, you can consult our dedicated in-depth articles. Find out more about professional opportunities and working conditions in the sector by visiting the page with job offers.

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Source: admin.ch