Our Test Vehicles: Privacy Information

Among other things, comprehensive testing and validation operations are required for the implementation of highly developed driver assistance functions. This takes place partly on public roads, which is why such a vehicle can sometimes cross your path.

Our Test Vehicles

In order to minimize the number of traffic accidents in the future and to make road traffic safer in general, Altran records the vehicle environment with its test vehicles using various optical sensors with the aim of improving vehicle algorithms. The vehicle algorithms are an important building block for autonomous driving and traffic in the future.

With the use of a test vehicle, it can also happen that people and vehicle license plates in the surroundings of the vehicle are recorded and stored. The test vehicles are not automated vehicles. In particular, the vehicles do not have an active system that can take over the longitudinal and lateral guidance of the vehicle.

Our Data Protection Measures

Before the operation of the test vehicles, the applicable national law was checked in detail and is complied with by the driving project.

In preparation of the test drives, a data protection impact assessment and risk assessment was carried out by our data protection officer. Due to the implementation of appropriate technical and organizational measures, Altran guarantees that personal data is processed in accordance with data protection laws and stored within the framework of the legal requirements. The data will not be published or made accessible to third parties. The collected data is only used for internal projects.

The labeling of the vehicles also ensures that those affected can assert their claim of possible data protection rights – in particular their right to have the data deleted.

The Legal Basis

Capgemini has thoroughly checked the legal basis for the processing of personal data within the scope of the test drive and has assured that the data protection regulations according to Art. 6 Para. 1 lit. f GDPR are complied with.

Below we would like to inform you about your rights. If you have any further questions about the handling of your data or would like your data to be deleted, you are welcome to send us an email at SM-DE-Data-Collection@altran.com or write to the following address:

Altran Deutschland S.A.S. & Co. KG
Frankfurter Ring 81
80807 Munich
GERMANY

Subject Rights

All persons affected by the processing of this data can assert certain rights with us under the GDPR and other relevant data protection regulations.

It is possible that in certain situations we may not be able to provide information about all data due to legal requirements or the information available to us. If this is the case, we cannot retrieve the data of the recorded person without receiving additional information. This is necessary because the recorded people in the periphery of the test vehicle cannot be identified without additional information. In addition, such identification is not necessary for the purpose pursued by Altran. For these reasons, we are not legally allowed to carry out any additional data processing for identification purposes. It is possible that your rights may be excluded in such cases under Art. 15 to 20 GDPR. It is also conceivable that we will not be able to identify the people recorded, even with additional information, and therefore cannot say who the people concerned are in the recordings. In addition, your data subject rights are restricted by the rights of others and by the obligation to store the data for other legal reasons.

You can object directly during or immediately after the data collection by the test vehicle and ask the driver to delete the relevant data. This can happen if, for example, you are a pedestrian in the camera field and notice the recording.

According to the GDPR, all persons concerned have the following rights against Altran:

Right to information (Article 15 GDPR):

You can request information about the data we hold about you at any time. This information relates to the following factors: the categories of data that we process, the purposes for which we process your data, the origin of the data if we have not collected it directly from you and, if applicable, the recipients to whom we transmit your data to. We will also provide you with a copy of your data at no cost. If additional copies are required, we reserve the right to charge you for them.

Right to rectification (Article 16 GDPR):

You can ask us to correct your data. We always take appropriate measures to ensure that the data that we hold about you and process on an ongoing basis is correct, complete and up-to-date, in each case based on the most up-to-date information available to us.

Right to erasure (Art. 17 GDPR):

We can also request the deletion of your data at any time, provided that the legal requirements for this are met. According to Art. 17 GDPR, this may apply if:

• the data are no longer necessary for the purposes for which they were collected or otherwise processed;
• you revoke your consent, which is the basis for the data processing, and there is no other legal basis for the processing;
• you object to the processing of your data and there are no overriding legitimate reasons for the processing, or you object to data processing for direct marketing purposes;
• the data has been unlawfully processed, unless the processing is necessary to ensure compliance with a legal obligation that requires us to process your data;
• in particular with regard to statutory retention periods;
• to establish, exercise or defend legal claims.

Right to restriction of processing (Article 18 GDPR):

The restriction of the processing of your data can be requested if:

• the accuracy of the personal data is contested by the person concerned, for a period enabling us to verify the accuracy of the personal data,
• the processing is unlawful and you refuse the deletion of your data and instead request the restriction of use;
• we no longer need your data, but you need it to assert, exercise or defend legal claims;
• You have lodged an objection to the processing, as long as it is not certain whether our legitimate reasons outweigh yours.

Right to data portability (Art. 20 GDPR):

As soon as your request is available, we will transfer your data to another responsible body, provided this is technically possible. However, this is only possible if the data processing is based on your consent or is necessary to create a contract. Instead of a copy of your data, you can also request that we transfer the data directly to another person in charge that you name us.

Right to object (Art. 21 GDPR):

You can object to the processing of your data at any time for reasons that arise from your particular situation, if the data processing is based on your consent or on our legitimate interests or those of a third party. In this case, your data will no longer be processed. The latter does not apply if we can demonstrate compelling legitimate grounds for processing that outweigh your interests or if we need your data to assert, exercise or defend legal claims.

Deadlines for the fulfillment of data subject rights

We always aim to respond to all requests within 30 days. Depending on the specific rights of the data subject or the complexity of your request, this period may be longer.

Complaint to supervisory authorities

Altran takes your concerns and rights very seriously. However, if you feel that we have not adequately addressed your complaints or concerns, you have the right to lodge a complaint with a competent data protection authority.

Contact

If you have any further questions, please contact the data protection officer, Mr. Frank Hebestreit, at dpocapgemini.de@capgemini.com