How does Cyclomedia manage my privacy?
Processing of personal details in our photography from the public road
Cyclomedia produces Cycloramas (360-degree panoramic photographs) taken from the public road and makes use of public geometric and land-registry data. It is permitted to take photographs from public roads. The street level photographs may also record personal data, on the basis of which Cyclomedia conducts its activities in accordance with the requirements of the General Data Protection Regulation (‘GDPR’). In the street level images collected by Cyclomedia, faces and license plates are made unrecognizable by 'blurring'. The blurred images are stored in a database and are made available to Cyclomedia's customers via a closed online platform.
Purpose of the data processing and lawfulness
Cyclomedia takes photographs from the public road in order to map the environment and has a legitimate interest to process potentially visible personal data in street level photographs pursuant to article 6.1 sub f GDPR. This legitimate interest includes the freedom to conduct a business as included in Article 16 of the Charter of Fundamental Rights of the EU and the resulting interest in being able to best serve its customers, other stakeholders and society as a whole. The data processing purposes consist of recording and processing street level photographs in a database in order to – under stringent conditions- make these photographs available to public and private organizations.
The image material collected by Cyclomedia provides a better understanding of the outdoor space and thus contributes to a social interest in better understanding and absorbing the increasingly complex and rapidly changing environment. In order to arrive at future-proof solutions for current themes in the field of climate change (e.g. the amount of green space in urban areas), mobility (e.g. parking facilities for electric vehicles), livability (e.g. type of buildings and green areas) and safety (e.g. escape routes during incidents or events), a transparent, accurate and complete overview of the outdoor space is necessary. In short, the interests of society as a whole benefit from the data processing carried out by Cyclomedia. A number of examples illustrate the importance of the use of street level photographs by Cyclomedia's customers:
- Municipalities: performance of public duties relating to the outdoor space, where it is necessary for them to have an unambiguous picture of this outdoor space. This enables the municipality to serve its citizens better, among other things by means of more adequate enforcement, improvement in communication with citizens and efficient execution of tasks.
- Control rooms, the police and the fire brigade: virtual investigation of the environment before actually responding to incidents or calamities or before arresting people. This is not only in the interest of the control room, fire brigade and police, but also in the interest of local residents.
- Network managers: digitalization of home connections (such as gas pipelines) to improve safety for residents during the construction and maintenance of these home connections.
- Infrastructure companies: construction and management of telecom networks, such as fibre optic and 5G networks that serve a social interest and that can be better prepared and realized through visual inspection and analysis of the entire outdoor area by means of Cyclomedia images.
- Housing corporations: visual inspection of the outside of buildings in order to obtain a clear indication of the state of maintenance and the liveability of the related buildings, which serves the interests of residents and local residents.
In order to be able to visualize the outdoor space on a large scale, thoroughly and in high quality and to be able to offer this (blurred) image material to customers in a database via a closed platform, it is necessary to process the (personal) data that is visible from the public road. This is necessary in order to be able to generate an overview of the outdoor space in such a way that it is comparable to what a person observes when he or she physically visits the same location.
In addition, the processing of certain data, which may sometimes be regarded as personal data (including houses), is necessary in view of the purpose for which these images are used, such as:
- Municipalities for e.g. purposes of:
- Exercising property related taxes;
- Registration of addresses and buildings;
- issuing and enforcing various permits, such as building permits, entrance permits, felling permits and advertising signs;
- inspection of building plans;
- verification of development plans;
- (re)development of municipal areas.
- Municipalities, provinces, water boards and other source holders for the purposes of digital mapping, such as the Key register Large-scale Topography (in Dutch: Basisregistratie Grootschalige Topografie, BGT) in the Netherlands.
- Land Registry for the management digital maps;
- Police forces for the purpose of observation and preparation of arrests;
- Housing corporations for the construction, conversion, management and maintenance of buildings;
- Network suppliers for the planning, realization, maintenance and repair of home connections;
- Engineering companies for assessing the impact of a project on existing buildings.
The interests of Cyclomedia and third parties, including society as a whole, are weighed by Cyclomedia against the interests and the fundamental rights of data subjects in relation to the protection of personal data. It plays a role in this respect that virtually all data visible on the imagey cannot be regarded at all or only as insensitive (personal) data that is already visible in the outdoor space. As a result, the potential adverse consequences and risks for any data subjects involved are minimal.
In addition, Cyclomedia has put in place various safeguards to prevent and limit any undesirable consequences for data subjects as much as possible. One of these measures concerns 'blurring': because faces and license plates are not relevant to the purpose of the processing, Cyclomedia uses an advanced software tool developed in-house that automatically detects faces and license plates in the images and makes them unrecognizable.
Cyclomedia's images are not publicly available. In addition, customers only gain access to Cyclomedia's visual material after the raw data has been blurred by Cyclomedia's software tool. Further, customers are not granted access to the entire dataset, but only to the relevant geographical areas within the imagery database, which they need for their own purposes.
Cyclomedia is of the opinion that its interests in combination with the interests of its customers in principle outweigh the invasion of the privacy of data subjects, also because Cyclomedia has taken measures to minimize this infringement, as further explained under 'Storage and security'.
Storage and security
The street level photographs produced by Cyclomedia are stored in order for Cyclomedia to fulfil its purposes of processing and its contractual obligations with customers. Storage of the database of street level imagery collected within European countries takes place within the European Economic Area. In the street level photographs that Cyclomedia records, stores and makes available to her customers via a web application, privacy-sensitive information, namely faces of recognizable persons and/or license plates of cars, are being made unrecognizable (‘blurred’). Cyclomedia has also set up various organizational and technical measures to ensure that unauthorized access to the data can be prevented:
- Storage of the raw visual material - before the execution of the blurring - in a non-open proprietary data format;
- Separate processing of image material and other data;
- Storage on strictly secured servers;
- Restriction of access for individual users via username/password;
- Informing employees of their obligations regarding the lawful processing of the image material and the data derived from this material;
- Establishing a reporting process for security incidents (data breaches).
Information and supervision
Depending on the country in which Cyclomedia captures street level imagery, Cyclomedia uses different types of media to inform the public abouts its activities. Cyclomedia also provides information about current and planned collection projects via its own website.
Cyclomedia has appointed an internal supervisor on the processing of personal data, a Data Protection Officer (DPO). The DPO supervises the adoption and compliance with the GDPR and can be contacted via the contact details below.
If you are involved in our photographs as a data subject (for instance, because your house has been photographed or because you think you yourself are visible within our photographs), you can request access, rectification, erasure and restriction of processing. In addition, you can raise objections to the use of your personal data. You can do this in writing: by e-mail to [email protected], through the contact page on our website, or by post to the following address:
Cyclomedia Technology B.V. Van Voordenpark 1b 5300 CE ZALTBOMMEL The Netherlands
If you have an access request, we may ask you to prove your identity, in order to prevent abuse.
You have the right to lodge a complaint with the Dutch Data Protection Authority.
When we drive around in your environment
Cyclomedia captures data from the public space in several European countries. Click on the button below for an up-to-date overview of the running data capture projects in Europe.