On-road driving

Sensor Data Privacy Notice

European New Car Assessment Programme ivzw / aisbl (“Euro NCAP”), Mgr. Ladeuzeplein 10, 3000 Leuven, Belgium, respects your privacy when handling personal data that may be captured during on-road vehicle testing using sensor recordings in the public domain.

This Privacy Notice explains how Euro NCAP collects, processes, discloses and transfers personal data and describes your related rights. It complements the general Euro NCAP Privacy Statement available on our website.

Categories of personal data processed, purpose of the processing and legal basis

During vehicle testing activities, Euro NCAP may record raw sensor data using equipment installed in test vehicles. This may include data from cameras, radar and/or LiDAR sensors, which is recorded using data recorders and stored on local storage media.

These recordings capture the environment surrounding the test vehicle. As a result, they may incidentally include limited personal data, such as images of pedestrians, drivers, cyclists or vehicles present in public road traffic.

The data is not collected for the purpose of identifying individuals and is not analysed or filtered to identify specific persons or vehicles (for example by recognising faces or licence plates).

Sensors installed in the vehicle capture a fixed and limited field of view around the test vehicle and cannot be swivelled or remotely controlled. Radar and LiDAR data typically do not allow the direct identification of individuals. No acoustic recordings are made. The recordings are therefore limited to what is necessary for the testing activities.

Data captured during test drives is not combined with other datasets to identify individuals, nor is it used to make decisions about identifiable persons. Euro NCAP does not seek to identify road users and does not allow others to do so using this data.

The recorded sensor data may be processed for the following purposes:

• Vehicle safety research and testing activities
• Evaluation and development of driver assistance and safety technologies
• Analysis of real-world traffic scenarios relevant to vehicle safety

As part of these activities, data may undergo labelling or annotation, where trained personnel mark objects in recorded data (for example vehicles, traffic signs, lane markings or pedestrians). This enables algorithms and analysis tools to recognise objects relevant to traffic safety.

Further processing may include object detection and tracking, allowing the analysis of how objects move in the recorded environment across consecutive frames.

In some cases, recorded data may also be used for environment modelling or mapping, allowing the reconstruction of traffic scenarios used for safety research and testing. These scenarios may be replayed in simulation or controlled testing environments.

Pre-recorded data may also be used to test and evaluate safety-related algorithms in replay environments, with results reviewed by authorised engineers.

The legal basis for the collection and processing of these recordings is Euro NCAP’s legitimate interest (Article 6(1)(f) of the General Data Protection Regulation) in conducting vehicle safety testing and research.

Transfer and disclosure of personal data

For the purposes described above, Euro NCAP may share personal data with the following recipients:

• Euro NCAP staff and carefully selected contractual partners, such as research partners, technical suppliers, contractors or service providers supporting the testing activities.

These partners are bound by contractual agreements, including data processing agreements where required, ensuring that they process data only on Euro NCAP’s instructions and in compliance with applicable data protection laws.

• Authorities or legal advisers, where disclosure is required by law or necessary for the establishment, exercise or defence of legal claims.
• Service providers acting as data processors, such as IT or hosting providers, who process data solely on behalf of Euro NCAP.

Retention and deletion

Sensor data collected during testing is retained only for the period necessary to fulfil the testing, research and validation purposes described above.

In certain cases, data may be retained for longer periods where necessary for documentation, quality assurance, scientific research, or legal compliance, or for the establishment, exercise or defence of legal claims.

Your rights

Under applicable data protection law, you may — where the legal conditions are met — have the right to:

• Obtain confirmation as to whether personal data concerning you is being processed and access to that data;
• Request the rectification of inaccurate personal data;
• Request the erasure of personal data;
• Request the restriction of processing;
• Object to the processing of personal data based on legitimate interests;
• Request data portability, where applicable.

Because the recordings are not intended to identify individuals and are not indexed by personal identifiers, it may be difficult to locate a specific person in the data. If you believe you appear in recordings made by a Euro NCAP test vehicle, you may provide additional information that could assist identification, such as the location, date, time and description of the situation.

Data Privacy Contact

Euro NCAP’s Data Protection Officer and the Data Privacy Organisation can be contacted for any questions, requests or complaints regarding data protection:

Email: privacy@euroncap.com
Post: Euro NCAP – Mgr. Ladeuzeplein 10 – B-3000 Leuven – Belgium

You also have the right to lodge a complaint with the competent data protection authority.

Further information on how Euro NCAP processes personal data can be found in the Euro NCAP Privacy Statement available on our website.