This Audio/Video Recording Policy (this “Policy”) describes the practices of Area X.O, operated by Invest Ottawa (“we”, “us”, “our”, “Area X.O”), with respect to our processing of personal information (“Personal Information”) from public spaces where our devices are located.
- Definitions
- “Applicable Privacy Laws” means laws applicable to the collection, use and disclosure of your personal information by us, including the Personal Information Protection and Electronic Documents Act, SC 2000, c 5.
- “Devices” means smart infrastructure devices deployed at the Intersection.
- “Device Data” means audio and video data collected from Devices to evaluate safety functions of an Intersection. Collected Data may include very limited Personal Information.
- “Personal Information” means information about an identifiable individual.
- “Personnel” means our employees and independent contractors.
- “Processing” means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “Security Incident” means the unauthorized acquisition of data that compromises the security, confidentiality, or integrity of Personal Information maintained by Area X.O.
- Commitment to Protect your Personal Information
- Area X.O prioritizes your privacy. As an organization, we aim to limit any Processing of your Personal Information to only what is necessary to further our research and development related to creating smart cities and smart mobility. Our aspiration to build a smart city has led us to installing our Devices at one or more intersections in Ottawa Ontario (each an “Intersection” and together “Intersections” as further specified in Schedule “A”). As you will see in this Policy, we take steps to protect your Personal Information and limit the disclosure and retention of any Personal Information collected through our Devices located at Intersection.
- Collection & Purpose
- We have various Devices at the Intersection that all record different information about such Intersection, such as wind speed, visibility, road conditions, and pedestrians crossing. We may collect this data 24 hours a day, 7 days a week, to assist us and our Research Partners (defined below) in the research and development of their smart city and smart mobility technologies.
- Device Capabilities. Each Device has unique capabilities, which enable our smart city research and development. Devices may be able to detect pedestrians crossing the road, provide thermal images and track such images in the intersection, measure the volume of traffic, precipitation, and prevailing visibility at the Intersection.
- Video Data. Video recordings may incidentally collect Personal Information, although we limit any such collection by irreversibly blurring individual’s faces and license plates. Further, the Devices’ field of vision is limited to only the Intersection, so that we may limit any Personal Information that may be captured in any video recordings.
- Audio Data. We may also use Devices that collect audio information, where the focus is on monitoring road conditions and road safety. Device Data may include limited Personal Information incidentally collected if you are talking to someone as you cross the intersection. We obfuscate your audio to render it unidentifiable to the best of our abilities. To protect your privacy, we conduct training and impose contractual safeguards with our Research Partners and Authorized Personnel.
- Accessing Personal Information
- Authorized Personnel. Only authorized employees, agents or independent contractors of Area X.O (“Authorized Personnel”) may access any Device Data, where required to assist with research and development. All Authorized Personnel receive privacy and security training to protect any Personal Information that may be captured on our Devices.
- Research Partners. We work collaboratively with many government and private companies (our “Research Partners”) who may have access to Device Data as required to further their research. All such Research Partners are bound my strict confidentiality agreements and must abide by privacy and security best practices to protect Device Data.
- Law Enforcement Requests. We will respond to requests for any of our Device Data where we are required to do so by a court order or otherwise at law. Where we are required to disclose any recordings, we shall only disclose information, including any Personal Information, that we are legally obligated to disclose.
- How we Protect Your Personal Information
- Safeguards. Your Personal Information is protected by various technical, administrative and physical safeguards. For example, we have contractual commitments with our Research Partners, and all faces and license plates are irreversibly blurred, to limit any ability to identify an individual. We also provide training to our Research Partners and Authorized Personnel, to ensure all parties abide by privacy and security best practices.
- Security Incidents. In the event of a Security Incident that create a Real Risk of Significant Harm, we will make reasonable attempts to notify the public of such Security Incident. Notification may be by any methods we deem reasonable to notify individuals who may have used the Intersection. Depending on the nature of the Security Incident, we may involve law enforcement or forensic investigators to mitigate any negative impacts you may face as a result of the Security Incident. We will take all reasonable actions to recover the data and limit its exposure. Further we shall take remedial and disciplinary actions, as applicable, to avoid any such Security Incident from occurring again.
- Retention & Deletion
- We do not intentionally retain your Personal Information. In the event that Personal Information is captured by a Device, we only retain such Personal Information as long as required to fulfill our research and development purposes, or as otherwise required by law. Further, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
- Updates to this Policy
- As our research and development evolves, we may revise this policy to reflect our privacy practices more accurately. We encourage you to periodically review this page for the latest information on our privacy practices.
- Questions & Contact Information
- If you have any questions or concerns regarding your privacy or our practices, you may contact our Privacy Officer at [email protected]
SCHEDULE “A”
THE INTERSECTIONS
The following intersections contain Devices, which are used in accordance with this Audio/Video Recording Policy:
- March Road and Terry Fox Drive, Ottawa ON
- Railroad crossing at March Road, Ottawa ON (45.337633 -75.909968)