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FMCI TEST DATA CAPTURE PRIVACY NOTICE
FMCI (Future Mobility Campus Ireland, we, us or our) equips its test cars and its Smart City infrastructure (located in the Shannon Free Zone West) with cameras to test products in real life environments. As our test cars drive on the roads or as we monitor traffic conditions for testing purposes , cameras collect photographs and videos in which your image may be captured. This may happen, for example, while you are walking on the street or driving a car alongside our test car. Even though these cameras may capture you, please be assured that we are not interested in identifying you, as a specific individual and solely focus on our technologies.
We take privacy very seriously. In this privacy notice we explain what data we capture and record with our test vehicles. This notice is meant for pedestrians and other people outside our test vehicles, and users of the Shannon Free Zone where our Smart City Test Bed is located.
1. General Principles
FMCI is committed to processing personal data in compliance with data protection regulations including European Global Data Protection Regulation (here after “GDPR”), and to respecting the rights of data subjects. Our testbed facility is used to develop, engineer and manufacture products that may trigger our obligations under GDPR, we take the principles of privacy and security by design into account at the time of engineering and developing such products. FMCI has in place a comprehensive data protection compliance programme that encompasses numerous policies, procedures, tools, forms and contractual clauses, as well as a detailed training and awareness program.
2. Who we are?
Future Mobility Campus Ireland (FMCI) is a company that has been established to create a space for organisations to research, develop and test innovative mobility solutions. FMCI has created a “lab” type environment within the Shannon Free Zone that will be accessible to organisations testing new methods of autonomous transport. Our address is Bay 80, Shannon Free Zone, Shannon, Co. Clare, Ireland, V14 WV82.
3. What personal data do we collect?
Our testbed facility is used for research and development activities in order to allow companies design and test innovative products, technology and applications related to automated vehicles and road safety. This includes testing products in real-life environments. As set out above, as our test cars drive on the roads, cameras within these test cars collect photographs and videos in which your image may be captured. Your image may also be captured as part of our Smart City CCTV system during testing periods.
Cameras as a part of our Smart City CCTV system shall be sited in such a way that they only monitor those spaces which are intended to be covered by the system and will not be installed in areas where people have a reasonable expectation of privacy.
An interactive map of the location of the roadside cameras can be found here.
We collect these photographs and videos solely for the purpose of improving the ability of products or systems embedded in test cars or our Smart City Infrastructure (CCTV) to distinguish between objects in their surrounding environments, and not for the purpose of identifying or making decisions about you as an individual. We apply stringent security measures to all personal data captured and we apply anonymization techniques to blur out your image from your surroundings. More information about these measures is provided in the sections on “how do we use personal data” and “how do we secure personal data” below.
4. How long do we store your personal data for?
FMCI will keep the recordings from our test cars in a secure environment for the time necessary to achieve the purposes for which it was collected or in accordance with any retention periods provided by applicable legislation including civil, criminal and commercial law.
Personally identifiable images captured by the video recording equipment are “personal data” are therefore subject to the provisions of the Data Protection Act 2018 (‘the Act 2018’) and the General Data Protection Regulation (EU) 2016/679 (‘GDPR’). Where cameras may capture personally identifiable images, these will be anonymised within 48 hours from the time of capture. 48 hours is necessary to allow for anonymization processing time.
Once we apply anonymization techniques to the photographs and videos captured by our test cars and Smart City Infrastructure (CCTV), we then do not consider that these contain personal data.
5. How do we use personal data?
We use the photographs and videos captured by our test cars and Smart City Infrastructure (CCTV) in support of our research, analysis or verification exercises. Specifically, we analyse these photographs and videos to understand the movement and behaviour of pedestrians or other drivers on the street, so as to develop and train detection sensors to be used in new vehicles (by us or on behalf of our customers), as well as the artificial intelligence technology used in connection with our products and services.
In all cases, the images we capture will never be correlated with other data that would allow us to identify you, nor used to make any decisions about you. We are not interested in identifying you, nor do we allow anyone else to identify you with our images. The images will only be used for statistical purposes in order to develop and enhance products and for scientific research aimed at improving artificial intelligence and all related technologies.
FMCI has developed specific protocols to manage the collection, transfer, and use of personal data collected during these tests, including by applying robust confidentiality and security measures to the data. FMCI will apply anonymisation techniques to the images (e.g. by blurring out any persons face present in these images) before analysing them unless it may have an impact on the quality of the images and on the tests results. FMCI will also apply anonymisation (blurring) to vehicle license plates that may be captured.
We may disclose personal data for the purposes we explain in this notice to our advisors (e.g., legal, financial, business or other advisors) and third parties permitted by law (e.g., the police, regulators, government agencies, or to judicial or administrative authorities).
6. What legal basis do we have for processing your personal data?
As set out above, we apply anonymization techniques to the photographs and videos captured by our test cars and Smart City Infrastructure (CCTV) and, therefore, we do not consider that these contain personal data. In the limited cases where we might retain details that would allow us to identify an individual, we rely on the following legal grounds:
We process the personal data contained in any photographs or videos collected by our test cars because it is necessary for the purposes of complying with legal obligations to which we or our customers are subject in relation to product safety. We also process this data in order to pursue our legitimate interests in ensuring the compliance of our products with technical requirements and specifications or with safety requirement, improving our products including assessing their performance and reliability in real-life environments. Finally, we may use personal data captured by our test cars for scientific research purposes, where the applicable jurisdiction allows us to do.
7. How do we share personal data?
FMCI’s Data Processors:
Where FMCI needs to outsource the processing of personal data to a third party provider, the data processor is carefully selected and bound by data processing agreements which require it to only use personal data for clearly identified purposes. The data processor’s personnel are also subject to strict non-disclosure agreements and training.
Clients as a third party:
Where a client as a third party is accessing video recordings as part of the contractual relationship, FMCI will ensure the following:
- the third party has been given appropriate notice regarding the security measures they should take in relation to the images – including required anonymisation processes.
- FMCI shall have in place appropriate and adequate procedures to ensure those guarantees are met.
- the written contract makes it explicit that the third party can only use the images in accordance with the instructions of FMCI.
- the written contract makes the security guarantees provided by the third party explicit, including the length of time data is to be stored.
Where a client is using their own sensors in particular cameras, FMCI will ensure that the client is made aware that the use of cameras and any subsequent recorded footage is subject to GDPR. In the event that a data subject invokes their data protection rights that applies to personal data captured by the client’s cameras or footage stored by the client, FMCI will pass on the request to the client.
Other third parties: We may disclose personal data for the purposes we explain in this notice to our advisors (e.g., legal, financial, business or other advisors) and third parties permitted by law (e.g., the police, regulators, government agencies, or to judicial or administrative authorities). We may also disclose photographs or videos captured during test drives of the products (but not names or other types of personal data) to members of the research and development community in the field of driverless cars technology for the purposes of allowing them to analyse these images for their own purposes and sharing their findings with us to improve the safety of the technology in this field as a whole. These engineers are also subject to strict non-disclosure agreements and terms of access. If you wish to see a list of members of the community with whom your personal data might have been shared, please contact our Data Protection Officer whose details are set out in the section titled “how to contact us?”.
Data export: In each case, where the sharing of personal data requires FMCI to transfer such data outside of the European Union, all necessary safeguards are implemented to maintain the protection of your personal data, including by entering into EU Commission-approved international data transfer clauses. If you wish to receive a copy of such clauses, please contact our Data Protection Officer whose details are set out in the section titled “how to contact us?”.
8. How do we secure personal data?
We are committed to ensuring data security, confidentiality and integrity. We seek to anonymise or pseudonymize personal data collected as part of our research, development and testing activities.
Our global Data Protection Compliance programme includes training, controls, policies, procedures and guidelines that help us develop and maintain cultural, organisational, physical and technical measures to ensure the security of your personal data.
This includes:
- The Data Processor Policy which imposes on data processors contractual terms consistent with the GDPR
- The Policy for International Transfer of Personal Data which requires FMCI employees to ensure that FMCI enters into EU Commission-approved international data transfer clauses which are mandatory where data is transferred outside of Europe
- Personal Data Breach Notification Procedure
- Non-disclosure agreements
- Mandatory training programs
- Tools and methods
Audits and controls
9. Your rights in relation to personal data
Where the collection of your personal data results from on-the-road recordings, our recording vehicles endeavour to notify data subjects of the fact that their images are being captured, which allows them to access the relevant privacy notices issued by FMCI and to further understand the purpose of such data collection and how it is processed.
The Smart City Infrastructure CCTV system located in the Shannon Free Zone West has privacy notices located around the Shannon Free Zone which also allows data subjects to access the relevant privacy notices issued by FMCI and to further understand the purpose of such data collection and how it is processed.
You have the following rights:
- The right to access the information we hold about you.
- The right to require us to rectify any inaccurate information about you without undue delay.
- The right to have us erase any information we hold about you in circumstances such as where it is no longer necessary for us to hold the information for your use of our services or if you have withdrawn your consent to the processing.
- The right to object to us processing information about you such as processing for profiling or direct marketing.
- The right to ask us to provide your information to you in a portable format or, where technically feasible, for us to port that information to another provider provided it does not result in a disclosure of information relating to other people.
- The right to request a restriction of the processing of your information.
- Where our processing of your information is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.
If you are unsatisfied with our use of your personal data or our response to any requests by you to exercise any of your rights, then you have the right to complain to the Data Protection Commission. See below contact details:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Email: [email protected]
Phone: +353 57 868 4800 / +353 761 104 800
10. How to contact us?
Should you have questions or concerns about data protection, your personal information, or should you wish to file a complaint, please contact FMCI’s Data Protection Officer whose details are:
Data Protection Officer,
Future Mobility Campus Ireland CLG,
Bay 80,
Shannon Free Zone,
Shannon,
Co. Clare,
Ireland
V14 WV82
Email: [email protected]
11. What will happen if we change our privacy notice?
This notice may change from time to time, and any changes will be posted on our website and will be effective when posted. Please review this notice each time you use our website or our services. This notice was last updated on the date appearing on the cover hereof.