POLICY ON THE USE OF DASH CAMS

The purpose of this privacy policy is to provide information on the processing and usage of personal data, collected on test tracks and public roads by dash-cams, operated with relation to vehicle safety functions tests carried out by TÜV Rheinland-KTI Ltd.

The protection of personal data is a high priority for us; therefore we make sure that our services are always provided in harmony with the existing data protection regulation and other relevant legislation.     

Content

Principles and purposes (why personal data is collected)

Data collection and processing (how personal data is collected and processed)

Legal basis for data processing

Data subjects (who does this policy apply to) and personal data processed (what data is used for processing)

Recipients (who the collected personal data is shared with)

Duration of data processing (how long your personal data is processed)

Automated decision making

Protection (how the collected personal data is secured)

Rights (what rights do you have with respect to your personal data we process)

Data controller (who is responsible for the processing of your personal data)

1. Principles and purposes

Nowadays, as road safety remains a paramount concern, the integration of Advanced Driver Assistance Systems (ADAS) is revolutionizing how we approach vehicle safety and driver responsibility. ADAS technologies, including adaptive cruise control, lane departure warnings, automated emergency braking or intelligent speed assistant, provide real-time assistance to drivers, significantly reducing the risk of human error and preventing accidents. The advances in ADAS and ISA (Intelligent Speed Assistance) systems promote safer driving behaviors and fostering a more secure road environment for all users. However, for the adequate testing of such systems, it is essential to test them both on test tracks and in real road traffic conditions.

TR-KTI carries out, among other, vehicle testing services for its customers. In cases, we use dash-cam footage to show and further analyze the performance of the above-mentioned systems during real-world driving conditions and as evidence of our work. On the one hand we gather essential data on the operation of the systems, while, on the other hand we verify that the measurement results and deliverables match the vehicle's performance accurately. Thanks to the information gathered from the collected data, further development of the systems can be made improving vehicle and road safety and increasing the number of accidents averted. 

2. Data collection and processing

Data collection takes place, as part of a driver assistance system development project, while our marked test vehicles are driven on public roads and test tracks. Our vehicles are equipped with cameras (so called dash cams) that monitor the surroundings and record pedestrians, cyclists, other drivers in or on vehicles, licence plates and surrounding objects in the vicinity of our test vehicles.

The collected data (video recordings, still-images) is handled, stored and analyzed by our expert team for validation of the vehicle operation. The recoding is safely stored and only accessible for our authorized experts. Due to the nature of our service and as a principal we place especial attention that in no part of the processing action do we carry out

• identification of individuals,
• extraction of personal data

3.   Legal basis

The legal basis of the processing is our legitimate interest (General Data Protection Regulation, Article 6, paragraph 1, letter f)). Our interest in the processing of the collected data lies in the purposes of testing and development of driver assistance systems and the verification of service provision and the results obtained.  

4. Data subjects and personal data collected

Within the scope of our vehicle safety functions tests we (might) capture the following personal data:

• Faces, identifying characteristics and behaviors of road users and other individuals in the vicinity of the test vehicles
• Surrounding environment of road users
• License plates, identifying characteristics, and surroundings of vehicles and other objects near the test vehicles
• Acoustic information from the area surrounding the test vehicles.

5. Recipients of the collected and/or processed data

In principle, we don’t provide the collected and/or processed personal data to any third party. In cases when we need to provide recorded evidence (video footage, still-images or acoustic information) for verification or any other purposes, we only do so following data masking and blurring of all personal information (including faces, license plates, etc.).

The same principle applies when we share such data with road traffic authorities, research institutions or any other body engaged in road safety research and development activities. 

Transfer to 3^rd countries

In case we need to provide data to 3^rd country parties, we do so via the sharing of anonymized data, that cannot be associated with any natural person.

6. Duration of data processing

The collected data will be processed and stored as long as is necessary for the research, development, testing and verification purposes but, as a general principle, data will be retained for up to 2 years after the project's completion, but not exceeding 5 years from the date of data collection.

7. Automated decision making

No automated decision making takes place in our data processing actions.

8. Rights of the data subjects

• Right to access: right to request information on whether there is data processing with respect to the data subject and on the actual data that is processed with respect to concerned data subject
• Right of rectification:  right to request correction of the data collected and processed with respect to the data subject in case the collected data is inaccurate or incomplete.
• Right to erasure: right to request deletion of the data collected and processed with respect to the data subject (unless there are legitimate reasons for the continued processing of the data)
• Right to restriction of processing: right to request a restriction on the processing of the personal data of the data subject in specific cases, such as contesting the accuracy of collected data
• Right of complaint: right to lodge a complaint to a regulatory or supervisory authority in case data subject believes that the data processing is not legitimate
• Right to object: data subjects have the right to object to the processing of their personal data in case the processing is carried out according to legitimate interest
• Right to data portability: data subjects have the right to request (the provision or transfer of) their personal data under processing in a structured, standard and machine-readable format    

9. Protection of the collected personal data

We are committed to ensuring data security, confidentiality and integrity in our service provision and handling of data and information received and collected. The recorded data we collect with respect to the vehicle safety functions tests is stored in a way that only selected members of the testing team can access it. Access to the data is secured by specific password. The collected data is deleted as soon as the legitimacy of data processing ceases. As far the transfer of the data is concerned, we seek to anonymise and/or pseudonymize all personal data collected as part of our research, development and testing activities.

10. Data controller and contact for data protection

The responsible entity for the collection and processing of your personal data with relation to vehicle safety functions tests is TÜV Rheinland-KTI Kft. (with address Thank Károly u. 3-5, 1119 Budapest, Hungary).

 

Contact details for requesting assistance or information with relation to data protection:

TÜV Rheinland InterCert Kft.

Gizella út 51-57.

1143 Budapest

adatvedelem@hu.tuv.com