RPAS RELATED PRIVACY AND DATA PROTECTION: PRACTICAL ADVICE FOR RPAS USERSRachel Finn, Trilateral Research Ltd.
TRILATERAL COMPANY PROFILE
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Privacy and data protection
Security and surveillance
Data Science
Crisis and disaster management
Research
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Impact assessment
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Trilateral Services
• Recently led a project for DG ENTR on the privacy, data protection and ethical issues associated with civil RPAS• Legislation analysis in 7 MS
allowing civil RPAS operations + the US and Switzerland
• Surveys with 149 stakeholders: 94 industry, 11 CAAs, 27 DPA and 17 CSO reps
• Workshops with 85 stakeholders
• 385 page report
MOTIVATION FOR DRONERULES.EU
• Professional users WANT to be responsible, but they do not know enough about privacy, data protection and ethics
• Private, recreational users are the least regulated category of user
• Commercial users are judged to be “medium risk”• Not nearly enough practical information for those using
RPAS in civil contexts
KEY FINDINGS
• Most RPAS operators may be collecting personal data• In a survey of 91 RPAS designers, manufacturers and
operators:
DETAILED FINDINGS
55% 97% 76%stated that their systems either captured members of the public, or that they did not know whether they captured members of the public
indicated that the data captured by the RPAS was recorded
indicated that the data recorded by the RPAS was stored
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• The most common application in Europe• Focused on infrastructure, not people• Footage of people limited to the “tops of their heads”
DRONES FOR INFRASTRUCTURE INSPECTION
• The “tops of their heads” ≠ anonymisation
• Employers, colleagues, etc. might recognise individuals on film
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• Drones have diverse: – Capabilities– Payloads– Operational contexts
RISKS TO PRIVACY & DATA PROTECTION ARE CONTEXTUAL
Using the same drone in with the same payload in a different context can raise new and different privacy and data protection impacts.
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• Most are small organisations or sole proprietorships• Most report only “basic” knowledge of European and
national privacy and data protection law• They will need to assess almost every operation to
ensure that they adequately consider privacy and data protection impacts
RPAS OPERATORS NEED SUPPORT
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Data protection, privacy and ethical issues content including:
– Legal information for professional users– Case studies in professional RPAS use– Privacy impact assessment template– Good practice guidelines– FAQs document
FOR PROFESSIONAL/COMMERCIAL USERS
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Data protection, privacy and ethical issues content including:
– Basics of RPAS privacy handbook– Case studies in private RPAS use– RPAS code of conduct on easy to carry card– Slideshow and quiz on the “do’s and don’ts” of RPAS
use
FOR RECREATIONAL / PRIVATE USERS
FOR PRIVATE/RECREATIONAL USERS
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• Reduce the presence of people in footage1• Only record when necessary2• Anonymise images3• Ensure transparency and consent4• Ensure purpose limitation5• Ensure the security of data collected6• Avoid storing unnecessary information7• Decide who is the data controller prior to the mission8
PRACTICAL ADVICE (IN THE MEAN TIME)
RACHEL FINN [email protected]