Survey privacy notice
RE.je is undertaking a project to create an accurate and up-to-date digital map of Jersey's built environment. This privacy notice explains how personal data may be collected and processed during this activity and outlines your rights under the Data Protection (Jersey) Law 2018 ("DPJL").
Who is responsible for the data
RE.je is the Data Controller for this project. This means RE.je determines the purposes and means of processing personal data.
Digital Jersey and Propelfwd act as Data Processors and process personal data on behalf of RE.je under a formal data processing agreement.
RE.je is registered with the Jersey Office of the Information Commissioner ("JOIC") under registration number 67906.
RE.je's Data Protection Officer can be contacted by email at dpo@re.je.
Purpose of the processing
The purpose of this project is to create an accurate and current digital representation of Jersey's public roads and built environment. The mapping data may support improved location accuracy across the Island and may assist services that rely on accurate property and road information.
Examples of potential uses include:
- improving mapping accuracy
- assisting navigation and location identification
- supporting services that rely on accurate property location data
The project is focused on capturing information about the built environment rather than individuals.
Lawful basis for processing
The lawful basis relied upon for the processing of personal data is Legitimate Interests under Schedule 2, Part 1(5) of the Data Protection (Jersey) Law 2018.
The legitimate interest pursued is the creation of an accurate digital street-level map of Jersey's built environment. Personal data may be incidentally captured as part of this environmental survey.
A Legitimate Interests Assessment and Data Protection Impact Assessment have been completed to ensure that the processing is necessary and proportionate and that the rights and freedoms of individuals are appropriately safeguarded.
What information may be collected
The survey vehicle collects several types of data while travelling on public roads. Most of the data collected does not identify individuals. For example:
- LiDAR data used to measure the shape of the environment
- geolocation data used to map the position of roads and buildings
- cellular survey data used to understand signal coverage
However, the 360-degree colour imagery may incidentally capture:
- images of individuals present in public places
- vehicle registration plates
- contextual visual information about public spaces
No audio is recorded.
No biometric templates, facial recognition data or profiling is generated.
How the data is collected
Data is collected using a clearly identifiable survey vehicle equipped with a 360-degree camera system and LiDAR sensors operating on public roads in Jersey.
The vehicle will display signage explaining that survey activity is taking place and will provide a QR code linking to further information and this privacy notice.
How the data is processed
Data is captured as raw packets and stored on encrypted systems within the survey vehicle.
The data is then transferred to a secure server environment located at the Digital Jersey Hub where it is processed through an anonymisation pipeline. Automated and manual techniques are used to detect and blur faces and vehicle registration plates before the imagery is used.
This process is designed to minimise the presence of identifiable personal data.
Data security
A number of technical and organisational security measures are used to protect the data, including:
- encryption of stored data
- zero-trust network architecture
- restricted access controls
- hardened operating systems
- security monitoring and audit logging
The capture system does not have open internet connectivity during survey operations.
How long personal data is kept
Raw imagery captured during the survey process may temporarily contain identifiable individuals or vehicle registration plates before anonymisation is applied. This raw identifiable data is retained for a maximum period of 18 months.
This retention period is required to allow the anonymisation process and associated quality assurance procedures to be completed. Captured imagery is processed in four-hour survey segments and each dataset undergoes three anonymisation passes using automated detection techniques designed to identify and blur faces and vehicle registration plates. Dip sampling and verification checks are carried out during this period to confirm that anonymisation has been successfully applied and to identify any systematic detection failures that require correction.
Once the anonymisation process and verification checks have been completed and the retention period has expired, the raw identifiable imagery is securely deleted.
Imagery that has been fully anonymised and no longer contains identifiable personal data may be retained for mapping purposes, as it no longer constitutes personal data under the DPJL.
Sharing of data
During the capture and anonymisation stages covered by this notice, identifiable personal data is not routinely shared with external organisations.
If individuals exercise their data rights, relevant extracts of imagery may be provided where legally required.
If anonymised data is later published or shared through mapping platforms, this will be subject to further assessment.
Your rights
Under the DPJL, individuals have a number of rights in relation to their personal data. These rights are designed to ensure that individuals have transparency and control over how their information is processed. If you believe you may have been captured in imagery collected as part of the RE.je street-level mapping survey, you are entitled to exercise these rights.
Right of access
You have the right to request confirmation as to whether your personal data is being processed and, where this is the case, to obtain access to that personal data. This is commonly referred to as a Data Subject Access Request. If you believe you may have been captured in imagery collected during the survey, you can request access to that data. To assist with locating the relevant imagery, you may be asked to provide approximate details such as the location and time where you believe the imagery was captured.
Right to rectification
You have the right to request the correction of inaccurate personal data. If personal data held about you is incorrect or incomplete, you may request that it be corrected. In the context of this project, this may apply if imagery has been incorrectly attributed or if information associated with a request requires correction.
Right to erasure
You have the right to request the deletion of your personal data in certain circumstances. This right is sometimes referred to as the "right to be forgotten". If you believe you appear in imagery collected as part of this project, you may request that the imagery be reviewed and removed or further anonymised where appropriate.
Right to restrict processing
You have the right to request that the processing of your personal data is restricted in certain circumstances. This means that the organisation may retain the data but will not continue to process it while a concern is investigated.
Right to object
Where processing is based on legitimate interests, you have the right to object to the processing of your personal data. If you object to the processing of imagery in which you appear, the organisation will review the request and consider whether continued processing is justified or whether the imagery should be removed or further anonymised.
How to exercise your rights
You can exercise your data protection rights in several ways.
If you see the survey vehicle collecting imagery, you can scan the QR code displayed on the side of the vehicle, which will direct you to the project information page and the online data rights portal where you can submit a request.
You can also submit a request directly through the online data rights portal by selecting the relevant option to enforce your rights. This portal allows you to submit requests for access, removal, objection or other rights relating to your personal data.
In addition, you may enforce your data protection rights through the cookie banner available on the RE.je website, which includes a link allowing you to submit a request directly to the data rights portal.
You can also contact the Data Protection Officer directly by email at dpo@re.je.
Where possible, please provide approximate information about the location and time where you believe you may have been captured and a detailed description of yourself, including clothing worn at the time or vehicle you were in, in order to help us identify the relevant imagery.
All requests will be reviewed in accordance with the DPJL.
Complaints
If you are concerned about how your personal data is being handled, you can contact the Data Protection Officer by email at dpo@re.je.
If you remain dissatisfied, you have the right to lodge a complaint with the Jersey Office of the Information Commissioner (JOIC).
Jersey Office of the Information Commissioner, 2nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT; https://jerseyoic.org.
Updates to this notice
This privacy notice may be updated if the project changes or if further safeguards are introduced.