Fair Processing Notice


Humanising Autonomy Ltd (“HA Ltd”) improves safety and efficiency of automated mobility systems by understanding and predicting human behaviour in cities. It uses visual camera sensor data as an input into its computer vision software, which outputs several datapoints about pedestrian behaviours and predictions in real time, allowing clients to inform their control systems and/or driver interfaces.

This document is HA Ltd’s Fair Processing Notice. HA Ltd (in the UK) processes video sequences of pedestrians, cyclists and other users of the road who interact with road vehicles (‘Road Users’), which have been captured by our client roadside or video cameras (‘Road User Data’). Our clients use our ‘Predictive Technology Service’ to improve road safety for all Road Users. As we do not have a direct relationship with Road Users this Notice aims to set out what we do with Road User Data, how we safeguard it and how individuals who believe their images may be contained within Road User Data can exercise their rights in respect of any Personal Data we hold about them.

HA Ltd is a controller that will determine the purpose and means of processing Road User Data. We will handle Road User Data according to Applicable Data Protection Laws (including but not limited to the General Data Protection Regulation 2016/679 (“GDPR”), the Data Protection Act 2018 (“DPA”) and any applicable national legislation implementing data protection laws. Our clients will usually also be a controller of the Road User Data they provide us with, so this Notice should be read in conjunction with their privacy notice.


Road User Data we obtain:

Where we provide a Predictive Technology Service to our clients, this will necessarily involve them providing us with Road User Data as referred to above. This may involve them providing video sequences captured from their vehicle or infrastructure cameras over a period of time to enable the type of behaviours that Road Users display to emerge, which is relevant to road safety and road accident prevention. Before we start the predictive analysis for a client, we will usually agree the timeframe and behavioural parameters our analysis requires, so that we are only provided with images or video sequences that are relevant to the client’s service requirements. The ability to map Road Users’ personal behaviors is integral to our road safety predictive model (e.g. eye movement, positioning of head etc.) so Road User Data will contain identifying features such as facial images. Our technology does not need to recognise who the individual is and is not able to identify named individuals, so we do not obtain or hold any names, contact or other personally identifying details of Road Users other than the video sequence.

This Notice includes our use of Road User Data provided by our clients, in respect of their mobility services provided in a particular geographical region, and with reference to a relevant road safety initiative that may be in place in that region at that time. Their providing us with Road User Data is a requirement of our Terms of Use of the Predictive Technology Service with them because we can’t provide such service without it.

Personal Data Type Collected

  • Road User Data in image/photo/video data;
  • Date information, time information, and location information;
  • Vehicle telematics data that relates to the movement of the vehicle (such as braking behaviour);
  • Road User Data may incidentally depict road traffic accidents and/or driving offences and/or injuries;
  • Road User Data may incidentally depict visible disability or conditions;
  • Vehicle condition and information vehicle registration does not form part of our predictive techniques.

Lawful Basis for Processing

  • Necessary for the performance of a task carried out in the public interest;
  • Necessary for the purposes of HA Ltd’s legitimate interests i.e. it is necessary for the purpose of providing our client with the Predictive Technology Service;
  • Where this involves processing special categories of Personal Data, this is necessary in the exercise of public functions which are of substantial public interest (public authority clients only).;
  • Where this involves processing of special categories of Personal Data, this is necessary for statistical purposes in the public interest.
  • Where this involves processing of special categories of Personal Data, it may also be necessary for the establishment, exercise or defence of legal claims or wherever Courts are acting in their judicial capacity.

Purpose of Processing

  • To collect information about pedestrians, cyclists and other road users interactions, when using the road for road safety purposes,
  • To improve the accuracy, effectiveness and safety of driverless vehicles;
  • For internal operations, including data analysis, testing, research, statistical and trouble-shooting purposes;
  • For analysis purposes, including machine learning development, service improvement and development, system reviews;
  • Road traffic safety;
  • To protect the trust and safety of pedestrians, cyclists, other road users and the general public.


The location where Road Users display road interaction behaviours is integral to our predictive road safety model so the location of the Road Users who appear in these images or video sequences, will be apparent and they will also be date and time stamped. Our clients capture or obtain video sequences in real time. We analyse real-time Road User Data on processing units of the client vehicle or infrastructure system.


The Predictive Technology Service uses images captured from client cameras sited on vehicles or infrastructure. These cameras record images, video sequences, and (in some cases) sound on the inside and outside of the vehicles. They will share the images or video sequences with us for the purpose of predictive analysis to improve road safety. Please refer to the privacy policy of the public transport provider in question for any other uses they may make of the images or video sequences.

Where lawfully permitted, we may be provided with access to specific image or video sequence data relating to the investigation in our legitimate interests of a specific complaint or incident referred to us in connection with our provision of the Predictive Technology Service to our client. We may also liaise with the client in relation to a disclosure by the client to law enforcement in connection with an incident that may arise.

For information in relation to our clients’ use of camera and Road User Data, and how to exercise your rights in relation to their use of your personal data, please see the respective clients’ privacy policy.


We may share Road User Data with the following:  

  • The client who provided us with the Road User Data in question, as part of the report and recommendations we deliver to them under the Predictive Technology Service.
  • We may also continue to use the Road Data after we have completed our analysis for the client who has provided this, to generally improve our predictive model. The personal data will be anonymized and pseudonymised as appropriate for the particular circumstances. We only share the resulting predictive analysis with other clients, not the images or video sequences themselves.
  • The relevant employees within our group Humanising Autonomy and our subsidiaries and affiliates who provide various support services.
  • The vendors and third party service providers we use to deliver our business, subject to us placing appropriate privacy restrictions on them to use only for that purpose and to protect the data.
  • Insurance companies, government agencies or law enforcement if necessary, or in order to protect our business, staff and customers and/or;
  • In connection with, or during negotiations of, the corporate transfer of assets.


We do not sell or share Road User Data with other people or non-affiliated companies for their direct marketing purposes. 


Road User Data will only be retained with identifying features where those features continue to remain an integral feature to improving the road safety predictive model.  Otherwise Road User Data is only retained for a period of up to six years after delivery of the Predictive Technology Service to the corresponding client to comply with our legal obligations, resolve disputes and enforce our agreements.


HA Ltd provides and operates the software platform which allows us to provide our clients with the Predictive Technology Service and is based in the UK.

Where the data is transferred or held on platforms outside the UK, we will ensure that it is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism.


Road User Data will be safeguarded in compliance with data protection law including when in transit between us and our client. Our data is stored in a secure web server and our onsite server and we use organizational and technical measures to ensure data is kept secure by us. We will have measures in place to ensure Road User Data is accessed by appropriate staff with relevant clearance.


Under Applicable Data Protection Laws, you have certain rights in relation to any personal data we hold about you:

  • You have the right to be told if Personal Data is held about you and, where that is the case, to be given a copy of that personal data.
  • You have the right to ask that any incorrect personal data about you is corrected. 
  • You have the right to object to the further use of any personal data we may holdor ask that your information be deleted. 
  • You have the right to request the processing of your information is limited.
  • You have the right to object to any use of your personal data in relation to  automated decision making. 
  • You have the right to lodge a complaint with a supervisory authority (the Information Commissioner’s Office in  the UK).

We may store Road User Data through the use and operation of our software and our Predictive Technology Service to clients and to develop and improve our predictive models, however the Road User Data we collect is limited in terms of our ability to identify this against a named individual.  As referred to above, we do not collect name, contact information or identity of Road Users.  As a result, in the event you make a request or enquiry involving you as a Road User, we may not be able to link the Road User Data with identifiers that you provide for that purpose. However where possible, we will carry out any reasonable actions to ensure that we comply with applicable data subject rights.


If you have any questions about this Privacy Notice, please contact us at:

Humanising Autonomy Ltd,

Somerset House,





[email protected]

We may revise this Privacy Notice, for example, if our data handling practices materially change. In this event, we will provide an updated version on our website.

Effective Date: 18/05/2020

Last Updated Date: 18/05/2020

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