SMLL Privacy Notice – Pilot Sites Activity
The Smart Mobility Living Lab (SMLL) is committed to protecting your information. The project is operated by a number of consortium partner organisations. TRL Ltd (TRL), the partner leading on Data Protection, has created this Notice to help answer questions you may have about how we protect and use the information we gather.
If you have any questions about our privacy practices or questions, requests or concerns regarding your information, please contact us via email to firstname.lastname@example.org.
TRL Ltd is the Data Controller for the purposes of the Data Protection Act 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679). You may contact our Compliance Team via email to email@example.com. Alternatively you may write to:
Nine Mile Ride
Berks, RG40 3GA
2 Legal basis for using your information
3 Information we collect
4 Special categories of personal data
5 How long we store data
6 Data recipients
7 Where we store personal data
8 How we keep information secure
9 Access to your information (Data Subject Rights)
10 Changes to our Notice
SMLL’s goal is to facilitate the safe development of autonomous vehicle technologies and related services for the benefit of all stakeholders including the future users amongst the general public.
Currently, we are using two locations to test the capabilities and performance of monitoring technology. This “Pilot Sites Activity” is providing us with useful information to help our future infrastructure installation.
In future, SMLL will observe how innovative technologies perform, are responded to, and can be best implemented in a real-world city environment. This will allow it to support both the needs of its customers and public safety. These technologies include, but are not limited to:
· Connected and Autonomous Vehicles (CAVs), also known as self-driving cars;
· Vehicle-to-Everything (V2X) connectivity; and
· Mobility and Logistics service applications.
Our purpose for collecting data at this stage of the SMLL is to assess the validity of, and improve, the equipment for use in further stages of the SMLL.
2. Legal basis for using your information
Under privacy and data protection legislation, the SMLL is only allowed to use personal information if we have a proper reason or 'legal basis' to do so. For the Pilot Sites Activity, SMLL has a “Legitimate Interest” to process your personal data in order to validate the use of, and improve, the equipment and its layout, configuration and design for use in later stages of the SMLL. We may process your personal data in this way where your interests and fundamental rights do not override our legitimate business interests.
3. Information we collect
SMLL is using video cameras mounted at the roadside in order to observe the movement of test vehicles through two signalised junctions, and their interactions with other road users whilst doing so. These cameras will capture some personal data as a result of their monitoring. The personal data collected are:
· live-streamed video of individuals moving through the monitoring sites.
· live-streamed video of number plates of vehicles moving through the monitoring sites.
The live-streaming of vehicle number plates may not constitute personal data as we are not likely to be able to identify an individual from the number plate, taking into account all objective factors. We have included it for completeness only.
The video equipment used provides a live stream. Information is only recorded temporarily, before being streamed to where it may be viewed and then automatically deleted. Personal data will not be retained long-term.
Data will only be captured from public areas on and around the highway. Privacy masking will be used to ensure no data is captured from private premises adjacent to the highway. This will be applied in-camera to block pre-determined areas of the field of view. This means that images of these private premises will never be captured.
In order to minimise data capture, the cameras will only be operational when there is an active testing session, such as when a test vehicle is in the vicinity of a pilot site. In addition, the cameras will not be used to record any sound.
4. Special categories of personal data
We do not intentionally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However, we may process Special Categories of Personal Data where it is publicly visible and picked up by the equipment we use.
5. How long we store data
The data will be stored only for as long as it is relevant to the purposes above. This will be a short period of time during which the live-video stream is communicated to where it can be viewed at our office. No data is kept after the data containing the video has been streamed for viewing.
6. Data recipients
The live-streamed footage containing personal data will only be accessed by the Data Controller’s employees.
7. Where we store personal data
All information we gather is stored in our secure servers in the United Kingdom. At no point will any personal data be transferred outside the United Kingdom.
8. How we keep information secure
We have implemented administrative, technical, and physical security measures to help prevent unauthorised access to the data we hold. This includes the use of encryption to protect personal data contained within the live-streamed footage for the short period it is being stored, communicated and viewed.
We restrict access to information to only those employees, who need such access in order to operate, develop, improve, or deliver our programs, products, and services.
9. Access to your information (Data Subject Rights)
You have the following rights regarding your personal data:
1. Right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Notice.
2. Right of access
You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Notice). This is so you are aware and can check that we are using your personal data in accordance with data protection law.
3. Right to rectification
You are entitled to have your personal data corrected if it is inaccurate or incomplete.
4. Right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. Right to restrict processing
You have the right to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
6. Right to data portability
You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
7. Right to object to processing
You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling).
8. Right to make a complaint to the data protection authorities
You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your personal data or believe our processing of your personal data does not comply with data protection law.
If you wish to exercise any of your legal rights, please contact our Compliance Team, by writing to the address at the top of this Notice or by emailing us at firstname.lastname@example.org.
We may require you to prove your identity with approved identification before fulfilling your request.
10. Changes to our Notice
Any changes we make to our Notice in the future will be posted on our website. Please check our website frequently to see any updates or changes to our Notice.
Questions, comments and requests regarding this Notice are welcomed and should be addressed to our Compliance Team, by writing to the address at the top of this Notice, or by emailing us at email@example.com.