Ohio recognizes all four common law invasion of privacy claims:
• Unwarranted appropriation or exploitation of one's personality;
• The publicizing of one's private affairs with which the public has no legitimate concern;
• Wrongful intrusion into one's private activities; and
• False light privacy (Welling v. Weinfeld, 866 N.E.2d 1051 (Ohio 2007)).
Engaging in employee surveillance in a restroom constituted an invasion of privacy by “intrusion upon seclusion,” a state court found in Speer v. Ohio Dept. of Rehab. & Corrections, 68 Ohio Misc. 2d 13 (Ohio Ct. Cl. 1994). However, videotaping an employee in his front yard while investigating his workers’ compensation claims was not such an invasion (York v. General Electric Co., 759 N.E. 2d 865 (Ohio Ct. App. 2001).