How to Ensure GDPR Compliance in In-Car Cameras ??
- AutoEconnect Sessions
- Mar 27
- 3 min read
Since in-car cameras collect personal data (driver faces, passengers, surroundings), they must comply with General Data Protection Regulation (GDPR) in the EU. GDPR requires that all personal data be collected, stored, and processed legally and securely.
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1. Key GDPR Challenges in In-Car Cameras
🚨 Facial Recognition & Biometrics – Driver Monitoring Systems (DMS) track eye movements, which are sensitive data.
🚨 Video & Audio Recording – Dashcams and surveillance cameras capture individuals outside the car (e.g., pedestrians).
🚨 Data Sharing – If the camera data is shared with third parties (e.g., insurance companies, cloud storage).
🚨 Cloud Storage & Remote Access – If data is uploaded to cloud servers, it must follow strict encryption policies.
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2. GDPR Compliance Measures for In-Car Cameras
🔹 1. Lawful Basis for Data Processing (Article 6, GDPR)
• Vehicle manufacturers & fleet operators must have a valid reason for collecting video data.
• Example of Lawful Bases:
• Legitimate Interest: Dashcams used for accident documentation.
• Consent: If driver/passenger data is used for personalized services (infotainment, advertising).
• Legal Obligation: Some regulations require DMS for safety (e.g., GSR 2024).
📌 What to do?
✅ Ensure in-car camera data collection is legally justified.
✅ Get explicit user consent when necessary.
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🔹 2. Data Minimisation & Purpose Limitation (Article 5, GDPR)
• Only necessary data should be collected.
• Data should not be used beyond its intended purpose.
📌 What to do?
✅ Avoid continuous recording unless required (e.g., Tesla Sentry Mode activates only on suspicious movement).
✅ Limit biometric data processing (e.g., store facial data locally instead of cloud).
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🔹 3. Transparent User Information & Privacy Notices (Article 12, GDPR)
• Drivers & passengers must be informed about data collection, storage, and usage.
• Users should know who processes the data and for what purpose.
📌 What to do?
✅ Provide clear privacy notices via the vehicle infotainment system.
✅ Display a GDPR-compliant disclaimer when activating recording features.
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🔹 4. Secure Data Storage & Access Control (Article 32, GDPR)
• In-car camera footage must be stored securely to prevent unauthorized access.
📌 What to do?
✅ Encrypt stored videos & biometric data.
✅ Use local storage instead of cloud if possible.
✅ Apply role-based access control (RBAC) – only authorized personnel can access the data.
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🔹 5. Data Retention Policy (Article 17, GDPR - Right to Erasure)
• Video recordings should not be stored indefinitely.
• Users should have the right to delete their personal data.
📌 What to do?
✅ Implement automatic data deletion (e.g., delete recordings after 7 days unless needed for legal reasons).
✅ Allow users to erase their data via vehicle settings.
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🔹 6. Avoid Unnecessary Data Sharing (Article 44, GDPR - Data Transfer Outside EU)
• If data is shared with third parties (e.g., cloud services, insurers), GDPR compliance must be ensured.
📌 What to do?
✅ Avoid transferring data outside the EU unless adequate protection (e.g., SCCs, ISO 27001) is in place.
✅ Anonymize data where possible (e.g., blur faces in shared videos).
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3. Real-World Example: GDPR Issues in Tesla’s Sentry Mode
🚗 Tesla Sentry Mode (which records surroundings when the car is parked) faced GDPR scrutiny in the EU.
🔴 Issue: It recorded pedestrians without their consent, violating GDPR.
✅ Solution: Tesla introduced privacy controls allowing owners to disable recording.
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4. Summary: How to Make In-Car Cameras GDPR-Compliant
✅ Obtain user consent before recording personal data.
✅ Minimise data collection (record only when necessary).
✅ Provide clear privacy notices about what data is collected.
✅ Encrypt & securely store video data to prevent breaches.
✅ Allow users to delete their data at any time.
✅ Restrict data sharing to GDPR-compliant entities.
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