Data privacy notice on the collection of video, image and sensor data from connected test vehicles
This privacy notice explains how Manor Mobility Intelligence Ltd (“Manor Mobility Intelligence”, “we”, “us”) collects and processes personal data when marked test and engineering vehicles equipped with cameras and other sensors are operated on public roads and authorised test areas in Australia.
Potential addressees of this notice are road users, pedestrians, cyclists, passengers and other persons who may appear in the vicinity of a marked Manor Mobility Intelligence test vehicle during research, development, validation or data-collection activities.
1. Who is responsible?
Manor Mobility Intelligence Ltd is the controller of the processing described in this notice, unless a separate written agreement with a client specifies joint controllership for a particular project.
Our test vehicles may be operated on behalf of automotive manufacturers and technology partners. Where we process data jointly with a client, the relevant project documentation will identify the cooperating parties and their respective responsibilities.
2. Which vehicles and systems are covered?
Marked Manor Mobility Intelligence test vehicles may be equipped with:
- Multi-camera systems with different fields of view, focal lengths and sensor technologies;
- LiDAR, radar or other environmental sensors where required for a project;
- GNSS / positioning and vehicle telemetry;
- In-vehicle recording and logging systems.
Vehicles used for public-road testing are appropriately marked. Testing may take place on public roads, highways, urban environments and on private or closed test facilities where permitted.
The test vehicles are marked, for instance with the following or similar stickers, which are attached to the test vehicles:
3. What data do we collect?
Depending on the project, the following categories of data may be collected from the vehicle environment and the vehicle itself:
- Video recordings and still images of traffic, road infrastructure, road users and surroundings;
- Images that may incidentally include faces, clothing, vehicle registration plates or other identifying features;
- Acoustic data where microphones are installed for a specific test objective;
- Location, speed, time stamps and related metadata;
- Technical vehicle and sensor logs required for validation and quality assurance.
4. Purposes of processing
We process this data for legitimate interests related to automotive engineering services, including:
- Research, development, testing and validation of advanced driver assistance systems (ADAS) and automated driving functions;
- Vehicle performance, durability and environmental testing;
- Road-scene and traffic data collection for algorithm training, localisation and market adaptation;
- Quality assurance, incident review, project reporting and regulatory compliance;
- Anonymisation, pseudonymisation or blurring of personal data in accordance with project requirements.
5. Legal basis
Where applicable law requires a legal basis, processing is carried out on the basis of our legitimate interests in providing professional automotive testing and validation services, balanced against the rights and freedoms of affected individuals. Where required, we implement masking, minimisation and retention limits to reduce the impact on privacy.
Where we process data on behalf of a client, we may also act as a processor under a data processing agreement.
6. Recipients and transfers
Access to collected data is limited to authorised Manor Mobility Intelligence personnel and, where necessary for a project, to the client and its designated engineering partners under contractual confidentiality and security obligations.
Data may be stored on secure servers in Australia or, where a project requires it, transferred to approved cloud or engineering environments in other countries with appropriate safeguards.
7. Retention
Recordings and related metadata are retained only for as long as necessary for the purposes above, including project delivery, legal obligations and quality review. Retention periods vary by project and contract but are reviewed regularly. Data no longer required is deleted or irreversibly anonymised.
8. Your rights
Depending on applicable privacy law (including the Australian Privacy Act 1988 and, where relevant, the GDPR for individuals in the EU/UK), you may have rights to request access, correction, deletion or restriction of personal data concerning you, or to object to certain processing.
Because recordings are often collected in traffic without direct identification of individuals, we may not always be able to locate specific data without additional information (such as time, location and description of the scene).
9. Security
We apply technical and organisational measures appropriate to the sensitivity of the data, including access controls, encrypted transfer where supported, role-based permissions and secure storage on project-approved systems.
10. Contact and enquiries
Melbourne, Victoria, Australia
Email: ulikeaus@gmail.com
Please include “Connected test vehicle privacy” in the subject line and, if possible, the date, time and location of the recording so we can respond to your request.
11. Changes to this notice
We may update this notice from time to time to reflect changes in technology, projects or legal requirements. The current version is published on this page.