--- title: "Cameras and AI in the factory: Spanish law | BionicAdri" description: "What the law in Spain says about cameras and artificial intelligence at work covers prior notice, the committee, impact assessment and European bans." url: https://bionicadri.com/en/blog/camaras-ia-fabrica-ley-espana.html markdown: https://bionicadri.com/en/md/blog-camaras-ia-fabrica-ley-espana.md language: en updated: 2026-11-09 index: https://bionicadri.com/en/llms.txt publisher: "BIONICADRI SOLUTIONS S.L. · info@bionicadri.com · +34 604 87 17 35" translations: es: https://bionicadri.com/md/blog-camaras-ia-fabrica-ley-espana.md en: https://bionicadri.com/en/md/blog-camaras-ia-fabrica-ley-espana.md ro: https://bionicadri.com/ro/md/blog-camaras-ia-fabrica-ley-espana.md fr: https://bionicadri.com/fr/md/blog-camaras-ia-fabrica-ley-espana.md de: https://bionicadri.com/de/md/blog-camaras-ia-fabrica-ley-espana.md it: https://bionicadri.com/it/md/blog-camaras-ia-fabrica-ley-espana.md pt: https://bionicadri.com/pt/md/blog-camaras-ia-fabrica-ley-espana.md --- # Cameras and AI in the factory: what the law allows in Spain What Spanish law requires in order to install cameras in a plant and analyse them with AI: inform in advance, what happens with the works council, the impact assessment and what the European regulation prohibits. By [Liviu Diaconu](https://bionicadri.com/en/nosotros.html#fundador) 9 Nov 2026 7 min read Installing cameras in a plant is not prohibited. Nor is analysing their images with artificial intelligence. But both have rules, and they change depending on what the system looks at and what you use it for. This article sets out what the law says in Spain and cites each rule, so that you or your adviser can check it. It is not legal advice: it is the map for getting to that conversation knowing what to ask. ## Two different questions It is worth separating them. The first is whether you can view or record images of your employees. That is governed by the Workers' Statute and the Organic Law on Data Protection. The second is whether you can analyse those images with artificial intelligence, and there the European AI Regulation comes into play. ## What Spanish law says about cameras The employer may adopt the surveillance and control measures it considers most appropriate to verify compliance with employment obligations, with due regard for the worker's dignity (Article 20.3 of the Workers' Statute). Organic Law 3/2018 sets this out for cameras in its [Article 89](https://www.boe.es/buscar/act.php?id=BOE-A-2018-16673): - Images may be processed for that monitoring, always within the legal framework and its limits. - Employees and, where applicable, their representatives must be **informed in advance**, expressly, clearly and concisely. - If a flagrant unlawful act is captured, the duty to inform is deemed fulfilled by the video surveillance sign under Article 22.4. For day-to-day workplace monitoring, the sign alone is not enough. - There can be no cameras or sound recording in rest or leisure areas: changing rooms, toilets, canteens and similar. - Sound is only permitted where the risks to the safety of premises, property and people are relevant, with proportionality and minimum intervention. The same law provides, in Article 91, that collective agreements may add further guarantees. Check yours. ## Employee representatives If there is a works council, Article 64 of the Workers' Statute gives it two rights that matter here. The first is to issue a report, before the employer puts it into effect, on «the implementation and review of work organisation and control systems» (64.5.f). The second is to be informed of «the parameters, rules and instructions on which the algorithms or artificial intelligence systems that affect decision-making that may have a bearing on working conditions are based» (64.4.d). If you are going to use AI cameras to organise or control work, talk about this with your employment law adviser before installing anything. ## Data protection An image in which a person can be recognised is personal data. The GDPR requires a data protection impact assessment before processing where it is likely to result in a high risk to the rights and freedoms of individuals, in particular when new technologies are used (Article 35.1). Your system analysing images of staff with AI is a good reason to ask your data protection officer or adviser whether one is needed. ## What the European AI Regulation adds Regulation (EU) 2024/1689 brings two ideas that directly affect a plant: - **A prohibition.** Article 5.1.f prohibits AI systems from inferring a person's emotions in the workplace, except for medical or safety reasons. A system that inferred whether an operator is happy or unmotivated would be excluded. - **A high-risk classification.** Annex III, point 4, includes AI systems for monitoring and evaluating the performance and behaviour of people in the context of an employment relationship. Employers using them must inform the workers' representatives and the affected workers beforehand (Article 26.7), in addition to complying with other obligations. Monitoring a conveyor belt, a forklift crossing or a loading dock is not the same as scoring operators. A system is designed for the former or the latter, and the difference matters both technically and legally. ## How we approach it Today BionicAdri does not analyse video in real time: what works is the control room, the kiosk and the sensors. We install AI cameras on a bespoke basis, with a pilot on one line, and this is how we approach them: - It detects the workstation, the conveyor belt or the area, not the person. - No facial recognition, no ranking or scoring of workers and no inferring emotions. - No sound and no cameras in changing rooms, toilets or canteens. - Images are processed on your own server, at the plant or in Europe, and are stored for only a short time. Only alerts and numbers are retained. - We put it in writing in the proposal and review it with you and your adviser. ## A checklist to take to your adviser 1. What does the camera look at: an area or people? 2. What decision is taken based on what it sees: organising production or evaluating someone? 3. How and when will staff and their representatives be informed? 4. Where are the images processed and how long are they stored for? 5. Is an impact assessment needed? 6. Are there cameras or audio in rest areas? There shouldn't be. 7. Who receives the alert and what will it be used for? The law changes and its application depends on each case, so this does not replace your adviser. If you want to see how we would approach a pilot at your plant, see [AI for factories](https://bionicadri.com/en/ia-para-fabricas.html) or [tell us about your production line](https://bionicadri.com/en/contacto.html#formulario). ## Frequently asked questions **Do I have to ask workers for permission?** The law refers to informing, not to asking for consent: they must be informed beforehand, expressly, clearly and concisely, and their representatives too if they have any (article 89.1 of the LOPDGDD). If you are unsure about the legal basis for your case, consult your adviser. **Is putting up a CCTV sign enough?** Not always. The sign covers the duty to inform when a flagrant unlawful act is captured. For day-to-day workplace monitoring, staff must be expressly informed. **Can AI score my operators?** It's not something we install. An AI system to monitor and evaluate the performance and behaviour of people at work is considered high-risk under Regulation (EU) 2024/1689, and inferring their emotions is prohibited. - Cameras - Law - Industrial plant ## Related articles ### [AI for factories and industrial warehouses](https://bionicadri.com/en/ia-para-fabricas.html) ### [Computer vision in production](https://bionicadri.com/en/vision-artificial-produccion.html) ### [Security and compliance](https://bionicadri.com/en/seguridad.html) ## See it with your company's data We show you ADRI working on a real task of yours, in about 15 minutes. [Request a demo](https://bionicadri.com/en/contacto.html#formulario) [info@bionicadri.com](mailto:info@bionicadri.com) · [+34 604 87 17 35](tel:+34604871735)