14. August 2023
Introduction
Camera data collection has become ubiquitous in various domains, from security and surveillance to marketing, ADAS and smart cities. However, with the increasing concern for individual privacy, it’s important to integrate privacy by design and by default principles into camera data collection processes. In this blog, we’ll explore the key steps and best practices to implement these principles effectively.
Privacy by Design and by Default are foundational concepts that emphasize the proactive integration of privacy considerations throughout the entire lifecycle of a system, process, or technology. Privacy by Design encourages organizations to consider privacy aspects from the outset, while Privacy by Default mandates that privacy settings are automatically set to the highest level of protection by default, requiring minimal user intervention.
Thorough Data Impact Assessment
Before implementing any camera data collection system, conduct a comprehensive Data Protection Impact Assessment (DPIA). Identify potential privacy risks and assess the necessity and proportionality of data collection. This assessment should involve stakeholders from various disciplines, including legal, technical, and ethical experts.
Purpose Specification and Limitation
Clearly define the purpose of camera data collection and limit data collection to what is strictly necessary to achieve that purpose. Avoid collecting excessive or irrelevant data that could infringe on individuals’ privacy rights. Once you know what data you need to collect, you need to then understand if collecting that specific data is compliant with the GDPR or the relevant legislation in your country. It’s important to understand that just because you need specific data to improve the CX of your customers and ultimately be more competitive, this does not give you legitimacy to collect any video data you want.
Anonymization and Minimization
Apply anonymization techniques to mask personally identifiable information (PII) whenever possible. Additionally, minimize the collection of personal data. There are many ways in which you can anonymize your data such as pixelation, blurring, video redaction, synthetic data generation like Deep Natural Anonymization (DNAT) etc and also many different considerations you should consider when choosing the right provider. You can find a checklist here.
Granular User Consent
If individual consent is required for data collection, ensure that it is obtained in a clear, transparent, and granular manner. Users should have the option to provide consent for specific data collection purposes and be informed about the consequences of their choices. If you need publicly collected data (i.e. if you work for an automotive company, public transportation etc), you will not be able to get their explicit consent, and this would make your data collection noncompliant. If this is the case, you will need to anonymize that data.
Strong Data Security Measures and Regular Privacy Audits and Reviews
Implement robust data security measures to safeguard collected data. Use encryption protocols for data storage and transmission, restrict access to authorized personnel, and regularly audit and monitor access logs.
Conduct periodic privacy audits to assess the ongoing compliance of camera data collection processes with privacy by design and by default principles. Make necessary adjustments based on the audit findings.
Transparent Documentation and Proper Staff Training
Maintain clear and comprehensive documentation of your camera data collection practices. This documentation should include details about data processing activities, retention policies, security measures, and any third-party data sharing arrangements.
Last, you need to educate your staff, particularly those involved in data collection and processing, about the importance of privacy by design and by default. Provide training on data protection laws, ethical considerations, and best practices for handling personal data.
Conclusion
Integrating privacy by design and by default principles when collecting data from cameras is not only a legal requirement in many places, but also a way to gain people’s trust. When organizations plan ahead to protect privacy, they show they care about the customers whose data they collect. Anonymization is an easy way to ensure compliance but also one pillar that supports privacy by default. This approach helps make sure camera systems keep personal information safe, minimize data risks, prevent expensive penalties, and keep customers feeling secure and confident. If you would like to know more about the key legal aspects you need to consider when choosing an anonymization provider, you can check out our blog.
