Data Protection Policy on video recordings for the development of driver assistance systems and systems for automated driving.
In the following we will inform you about the data processing for the development of driver assistance systems and systems for automated driving in accordance with the legal requirements of the General Data Protection Regulation (in the following “GDPR”).
1. Context of the data processing
HELLA Aglaia Mobile Vision GmbH develops camera-based driver assistance systems and systems for automated driving. For the development of these systems, video recordings are made with test vehicles on public roads. The cameras and sensors used in the test vehicles record the road being driven on, buildings visible from the road, traffic signs, traffic lights, other road users, pedestrians, etc. (“video and sensor data”). This data is incorporated into the development of those systems and must be as realistic as possible to ensure the functionality of the systems.
For the security of the processing, the data are stored and encrypted in the test vehicles on specially secured hard disks before transferred to our server. Access to the data is restricted to employees who manage the data or need it for development. In no event will HELLA Aglaia use the data to identify a natural person.
2. Name and contact details of the data controller
This Data Protection Policy covers the data processing of the data acquisition by:
HELLA Aglaia Mobile Vision GmbH
12109 Berlin, Germany
(in the following „HELLA Aglaia“)
Tel: +49 (0) 30 2000 429-0
The data protection officer of HELLA Aglaia can be contacted via the address mentioned before, attn. data protection officer or via email to firstname.lastname@example.org.
3. Purpose and legal basis of processing of personal data
a) Video recordings
HELLA Aglaia is producing videos of public roads via front cameras and 360° cameras. The cameras are installed approximately at the level of the diver’s sight and record public roads. Inevitably, other road users, their vehicles and pedestrians are also affected. Purpose of the data processing is the development of camera-based driver assistance systems and systems for automated driving for vehicles. The detection of driving lanes, traffic lights, road signs, vehicles, obstacles, pedestrians, light sources etc. should improve road safety.
The processing of the video recordings are mandatory for development and testing of such systems. The data must be as close to reality as possible to ensure that the processing results in the development and test laboratory correspond as closely as possible to those in real use on the road. This is necessary to ensure that no malfunctions occur which could lead to serious traffic accidents.
The processing of personal data during the video recording is carried out for the purpose of development of camera-based driver assistance systems and systems for automated driving on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR.
At HELLA Aglaia the video recordings will be manually reworked by so-called label teams. All relevant features in the videos, e.g. driving lanes, traffic lights, road signs, vehicles, pedestrians, obstacles, light sources etc. are marked (“labeled”). Purpose of the labeling is to prepare the video recordings, that they can be used for development and testing of the systems. This step is necessary to ensure that the systems recognizes all relevant features and that no malfunctions occur which could lead to serious traffic accidents.
The processing of personal data during the labeling is carried out for the purpose of the utilization of the video recordings for the development and testing of the systems on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR.
If external service providers are instructed for the labeling, this is only done within the terms of an order processing contract in accordance with Art. 28 GDPR. With this contract, the service provider assures that the data will be processed in accordance with the GDPR and that the rights of the person concerned will be protected. In the case of a labeling by an external service provider, the data are stored and processed in the EU.
c) Software development and testing
The labeled video recordings are used for the software development. They are used to train the software in all relevant recognition scenarios, e.g. at day or night, different weather conditions and road types or different road users (e.g. vehicles, pedestrians, cyclists or obstacles). The labeled video recordings are also used to test the developed systems to verify the recognition rates. In this way, new systems can be tested in the laboratory with existing video recordings.
The processing of personal data (such as pedestrians and license plates) is carried out for the purpose of the (ongoing) development and testing of the systems on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR.
d) Anonymization of faces and license plates
In certain cases, e.g. when video data is shown to a customer or cooperation partner for presentation purposes, the video data is made anonymous in advance by a special software. The software marks each recognized face and license plate and overlays it with a randomly selected animated face or license plate. Even if this is not intended, the identification of a natural person on the basis of the anonymized video recordings would be impossible or only possible with disproportionate effort.
The processing of personal data is carried out for the purpose of anonymizing the video recordings and for the fulfilment of technical data protection on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR.
4. Transfer of data
The video recordings will not be transferred to third parties for any other purpose than the following:
a) Transfer in the context of projects
HELLA Aglaia may transfer video recordings to third parties as part of commercial or public development projects. The transfer of the video recordings serves the cooperation in the development of the camera-based driver assistance systems and systems for automated driving for vehicles and is carried out on the basis of our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR.
If a customer is based outside the EU and the data therefore must be transferred to a third country, is this done in compliance with the requirements pursuant to Art. 44 to 50 GDPR.
b) For other purposes
Apart from that we will only transfer your personal data to third parties, if:
- you have expressly given your consent pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR;
- in cases where transfer of your data is necessary for a legal obligation pursuant to 6 para. 1 sentence 1 lit. c GDPR.
5. Storage period
The storage period of the video recordings underlies the strict purposes limitation and data minimization. This means that the data are deleted when they are no longer necessary for the aforementioned purpose for which they were collected (see point 3.).
In addition, we store data, which are necessary for the development, in a permissible manner for a period of up to 30 years, taking into account the statute of limitations provisions of § 199 Para. 2 BGB (German Civil Code).
6. Data subject rights
You have the right:
- pursuant to Art. 15 GDPR to request information from us about the personal data stored about you;
- pursuant to Art. 16 GDPR to demand immediate rectification of inaccurate or completion of your personal data saved with us;
- pursuant to Art. 17 GDPR to demand deletion of your personal data saved with us;
- pursuant to Art. 18 GDPR to demand restriction of processing of your personal data;
- pursuant to Art. 20 GDPR to receive your personal data you have provided us in a structured, commonly used and machine-readable format or to demand transmission to another controller;
- pursuant to Art. 77 GDPR to lodge a complaint to a supervisory authority. You can contact the supervisory authority of our registered offices (https://www.datenschutz-berlin.de).
7. Right to object pursuant to Art. 21 GDPR
Pursuant to Art. 21 GDPR you have the right to object to the processing of your data at any time. In the event of an objection, we will no longer process your data. An exception exists if there are compelling reasons worthy of protection which outweigh your interests.
If you want to exercise your right to object, simply send an email to email@example.com.
8. Technical data protection and security
The processing of the data is subject to a comprehensive and strict data protection concept, which ensures the technical and organizational protection of the data at all time. This includes among others the following measures:
- the anonymization and encryption;
- an access authorization concept for the video recordings;
- a concept for handling the video recordings;
- measures to ensure the ongoing confidentiality and integrity of processing systems and services;
- deletion routines for video recordings.
9. Actuality of and changes to this Data Protection Policy
10. Information about the data processing on our website
Further information on the data processing when using our website can be found in the Data Protection Policy of our website.