Privacy information for passers-by: exterior cameras on MOIA’s autonomous test vehicles
1. What is this about?
MOIA is testing autonomous vehicles. The test vehicles have exterior cameras. Their images are transmitted live to MOIA’s Fleet Control Center. There, staff monitor the vehicles and support them remotely when needed (remote assistance). If you are near one of our test vehicles, you may appear in these images.
2. Who is responsible?
The controller is MOIA GmbH, Alexanderufer 5, 10117 Berlin, Germany. You can reach our data protection officer at datarequest@moia.io.
3. What data do we process?
We process live images of the vehicle’s surroundings. These may show people such as pedestrians, cyclists and other road users, as well as licence plates and lettering. Together with the images, we process the vehicle’s location, the time and trip data. If an incident occurs, we also process details of what happened, the people involved and any witnesses.
4. For what purposes and on what legal basis?
We use the images to make sure the test vehicles operate safely. Fleet Control Center staff approve driving manoeuvres of the self-driving system, trigger an emergency stop when needed, troubleshoot, and handle incidents and complaints. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interests are the safe operation of the test vehicles, the handling of incidents, and quality assurance and troubleshooting.
5. Are the images stored?
No. The images are only transmitted live to the Fleet Control Center. They are not recorded, not stored and not saved as still images. If an incident occurs, Fleet Control Center staff make a written note of what is needed to handle it, for example the location, time and course of events and, where necessary, the licence plate of a vehicle involved. We keep these notes for as long as we need them to handle the incident and to establish, exercise or defend legal claims. After that, we delete them.
6. Who receives the data?
A service provider supports us with remote assistance. We use IT and hosting providers for technical operations. All of them act as processors under Art. 28 GDPR and are bound by our instructions. We pass on incident details to the police, public authorities or insurers where this is required by law or necessary to investigate the incident. Your data is not transferred to countries outside the EU or the EEA.
7. Your rights
You have the right of access, rectification, erasure and restriction of processing. As the images are not stored, we cannot provide access to live images after the fact. Access to stored incident notes is possible.
Right to object: You may object to the processing at any time under Art. 21 GDPR on grounds relating to your particular situation. To do so, please contact datarequest@moia.io.
You can also lodge a complaint with a data protection supervisory authority. The authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information. You may also contact the supervisory authority where you live.
8. Other cameras on the vehicle
The test vehicles are also equipped with cameras and other sensors of the self-driving system. Mobileye and companies of the Volkswagen Group are responsible for the recordings made by this system. You can find information on this on the sticker on the vehicle and at https://www.volkswagen-nutzfahrzeuge.de/de/rechtliches/datenschutz/datenschutz-erprobungsfahrten-info.html (in German).