We believe strongly that the future of the Smart City has to be citizen-centric, and that keeping citizens’ data safe and private is critical to the success of this technology. As such, we have designed our solutions from the ground up to guarantee the privacy of every citizen, utilising privacy-by-design principles.
Privacy-by-design.
Our sensors are designed to provide accurate data on the usage statistics of road environments in a completely anonymous way. The system was developed using data protection-by-design principles and is fully compliant with GDPR. Our sensors do not collect personal data, and none of our clients can use our technologies to gather any kind of personal data or for enforcement purposes, ever.
Our sensors do not record or stream video footage. Under normal operation, the system processes all video locally, produces anonymous data feeds and discards the video within milliseconds. As such the system produces no personal data and therefore presents no privacy or personal data risk.
Data Security.
The software does not have the ability to identify anything unique about individual vehicles. We have also never done any work involving facial recognition and we will never do so as it violates our commitment to privacy.
The sensor software and memory is encrypted and all communication to and from the sensor is encrypted using industry standard HTTPs TLS1.3 security.
There are a small number of occasions when the sensors are not under normal operation. During initial setup of the sensor, it may be necessary to store up to an hour of video to allow us to configure and calibrate the system. Once set up, this video is also deleted. To continue to grow our image training set, which helps to improve system accuracy, we may, only with the permission of our clients, choose to extract a few sample images from each new sensor installation to add into our training set.
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Privacy Notice to the Public
This is a Privacy Notice for VivaCity Sensors. These sensors look like on the image.
A sign is located on the post mounting the sensor, to direct the public to this web page.
These sensors are not CCTV Cameras.
VivaCity sensors are designed to produce Anonymous Traffic Data (see an example below) on how roads are being used to support transport operation and planning. During normal operations, no personal data is produced by these sensors.
Anonymous Traffic Data: e.g. counts of different classes or road user
This Privacy Notice explains how, during short periods of system development and testing, video may be recorded. While this video is classed as personal data, it will not be used for the purpose of identifying any individual.
A typical sensor will record less than 1 hour of Video Data during its lifetime.
The short video data captured by these sensors are processed by Vivacity Labs Limited.
We take the protection of your data very seriously and have implemented appropriate technical and organisational measures to ensure its security. Only authorised personnel have access to the data and it is stored on secure servers.
Categories of Data: video data of public roads.
Data Sharing – Anonymous Traffic Data: We share data with our customers, including government agencies and transport planning authorities for the purposes of supporting and improving traffic flow and transportation planning. Some customers choose to open this data or share it further.
Data Sharing – Video Data: We blur any video data prior to sharing with our customers, including government agencies and transport planning authorities. This data is only shared to provide contextual information about the environment around the sensors, or to validate the accuracy of the Anonymous Traffic Data.
Data Retention – Video Data: A 10 minute video from each sensor is retained for the lifetime of the sensor deployment to test software updates. A subset of Video Data is retained for testing and developing the sensors.
Your Rights: You have the right to access, rectify or erase your personal data. You also have the right to object to the processing of your personal data and to lodge a complaint with the supervisory authority.
Changes to Privacy Notice: We may update this privacy notice from time to time in order to reflect changes to our data collection and processing activities. The latest version will always be available on our website.
If you have any questions about our privacy notice, please contact the Data Protection Officer at dataprotection@vivacitylabs.com.
This notice is in compliance with the General Data Protection Regulation (GDPR).
Vivacity Labs Limited Privacy Notice - Operation in the Republic of Ireland
1. Purpose of the road traffic surveys
Vivacity Labs Limited provides a video based sensor to produce anonymous data on how roads are being used to support transportation operation and planning. This includes counts of vehicles, pedestrians, and cyclists. During normal operation, no personal data is produced by our sensors. A 10 minute “Validation Video” is recorded, typically shortly after the sensor is installed to validate the quality of the anonymous data produced. While this Validation Video is classed as personal data, it will not be used for the purpose of identifying any individual.
We are committed to protecting such personal data in accordance with the Data Protection Act 2018, the General Data Protection Regulation (GDPR), and the Data Protection Act 2018 (Ireland). The purposes of processing personal data are to:
- Get accurate data on traffic, cyclist, and pedestrian movements at specified locations.
- Inform the correct design process.
- Improve safety for all road users at these locations.
2. Legal Basis for Processing Personal Data
The legal basis for processing personal data in traffic surveys is:
- Article 6(1)(e) of the GDPR: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Vivacity Labs Limited.
- Compliance with legal obligations, such as those under the Health, Safety, and Welfare at Work Act 2005 (Ireland).
3. Categories of Personal Data Concerned
Personal data processed in traffic surveys include:
- Incidence of cyclists, pedestrians, and vehicles.
- Images of cyclists, pedestrians, and vehicles will be processed in a manner that prevents individuals from being identifiable.
- The official authority for our customers in this case derives from the Road Act, 1993 – Section 13 – Responsibility of road authorities for the maintenance and construction of local road and Section 78 – Powers of inspection and survey.
4. Processing and Recipients of the Data
Data access is limited to Vivacity Labs Limited. Images will be recorded such that individuals are not identifiable, and only anonymized traffic movement data will be provided. No personal data will be shared with third parties except as required by law. Access requests will be processed in accordance with the Data Protection Act 2018, GDPR, and Vivacity Labs’ data protection policies.
5. Data Retention Period
A 10 minute video from each sensor is retained for the lifetime of the sensor deployment to test software updates. This retention period has been chosen in order to meet the Data Minimisation period of the GDPR, as it can be re-used to test any software updates during the life of the sensor instead of recording a new validation video.
6. Data Subject Rights
Data subjects have the following rights under the GDPR and the Data Protection Act 2018 (Ireland):
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object and to automated decision-making
For Data Subject Access Requests, and other queries please contact our Data Protection Officer (DPO) at dataprotection@vivacitylabs.com
7. Right to Lodge a Complaint
If you are not satisfied with a decision regarding your data or have concerns about data processing, you have the right to complain to the Data Protection Commission (Ireland). We recommend contacting Vivacity Labs Limited first to resolve the issue.
8. Contact Details for Data Controller and Data Protection Officer
Data Controller:
Address: 3 Haberdasher Street, London, N1 6ED
Email Address: dataprotection@vivacitylabs.com
Data Protection Officer: dataprotection@vivacitylabs.com
9. Changes to Privacy Notice
We may update this privacy notice from time to time in order to reflect changes to our data collection and processing activities. The latest version will always be available on our website.
This notice is in compliance with the Data Protection Act 2018, the General Data Protection Regulation (GDPR), and the Data Protection Act 2018 (Ireland).
Clear Communication.
We will always provide temporary signage in the vicinity of a sensor before gathering images for set-up, calibration or optional software training purposes. These signs state,
“New road space usage sensors installed, once fully operational they will only produce anonymous data. Video may be intermittently recorded at this location during this initial project phase, for the purpose of system development and testing”.
The images captured are low resolution and do not contain Personal Data as defined by the ICO.
ICO & GDPR.
VivaCity are registered with the ICO of the UK and Jersey to enable us to collect and hold image data for the purpose of developing software to extract anonymous data from video feeds. We act as the data controller for the software training process. We have carried out Privacy Impact Assessments for this work. If requested, we will not extract any training data from a given sensor.
Read more about our approach here or please contact us for further detail on our robust Data Privacy and GDPR policy.