Content scanning systems employ perceptual hashing algorithms to scan user content for illegal material, such as child pornography or terrorist recruitment flyers. Perceptual hashing algorithms help determine whether two images are visually similar while preserving the privacy of the input images. Several efforts from industry and academia propose to conduct content scanning on client devices such as smartphones due to the impending roll out of end-to-end encryption that will make server-side content scanning difficult. However, these proposals have met with strong criticism because of the potential for the technology to be misused and re-purposed. Our work informs this conversation by experimentally characterizing the potential for one type of misuse - attackers manipulating the content scanning system to perform physical surveillance on target locations. Our contributions are threefold - (1) we offer a definition of physical surveillance in the context of client-side image scanning systems; (2) we experimentally characterize this risk and create a surveillance algorithm that achieves physical surveillance rates of >40% by poisoning 5% of the perceptual hash database; (3) we experimentally study the trade-off between the robustness of client-side image scanning systems and surveillance, showing that more robust detection of illegal material leads to increased potential for physical surveillance.