These Q&As give you more information on Shoppar and how we have approached issues around data protection and in- formation security.
We want to make sure that you have all the information you need so if you have any further questions, please let us know.
What information will be collected?
The data collection algorithm interprets via computer vision anonymous “metadata” that describes the demographics and behaviour of an audience. The algorithm interpret age, gender, mood and how long an individual looks at the advert.
No image is forwarded from the camera unit or stored on device.
Does what we do uniquely identify the audience and what about data protection law?
The software does not uniquely identify the audience by itself. All data is anonymous and only describes the audiences’ metrics – age, gender, mood, attention and behaviour.
Whilst the metadata captured could not, by itself, be used to identify an individual, there is a possibility that it could be used in conjunction with other information you collect (such as sales data or CCTV recordings) to identify an individual. There is therefore a possibility that this information will count as personal data and will therefore be subject to data protection law. Accordingly, as a precaution, we have included the mandatory GDPR wording in our terms and conditions in order to give you additional assurance around data protection compliance.
The metadata will only be stored as long as it is being used for the purposes of customer analytics by the end user. After the usage period (or before if requested by you) all data will be deleted.
Are the images/video captured and processed by Shoppar cameras considered to be PII or is there an opinion that they are so transient that they avoid this categorisation?
All images are processed in real time. Their effective “life” is 1/30th of a second and are thus transient. As they are also disposed of immediately there are no issues around obtaining consent for their storage or future use. The simply cease to exist as they are generated.
Is all the processing and storage carried out in RAM, or is there a stage in the processing where files are written to more persistent storage? If so, how long is the average storage and how long is the maximum storage period?
All data is processed entirely in RAM and is never reaches persistent storage either locally or remotely. As mentioned above, the life of a unique image is approximately 1/30th of a second.
Are there any circumstances, including via hacking into the camera, in which videos or images could be stolen?
No system is 100% secure. That said, using best industry practice mitigates as much as possible the opportunities for malicious use or consumption of data from our system. The security models in the operating systems deployed rely on a white list of permitted activities, and unless the application, including malicious hacking applications, has explicit permis- sions for a particular function, eg using the camera, that application will be blocked from operating. As all potential PII is disposed of as quickly as it is generated, and the device has no whitelisted mechanism to store data, the potential for sensitive information to be compromised is as minimal as is reasonably possible.
How have the GDPR and Consent issues been addressed in your current live deployments?
The GDPR regulations require that anyone entering a space be notified of potential data uses that may require explicit consent for storing PII. As we do not store or transmit PII, there is no requirement for anything beyond the notice that there are devices on premises used for data analysis. The privacy line that we draw with the device, is “what can an employee with a clipboard and a checklist capture about customers on premises” By only providing aggregate metadata, and disposing of real time inputs, there is nothing that a customer would need to consent to store, just as a staff member could tick off relevant tick boxes for woman in her 40’s of likely ancestry.
Who has access to the data?
You will have access to view the data as it is interpreted into usable insights about the audience in data dashboards. Any Shoppar staff that have access to the data for processing and maintenance are all held to a strict non-disclosure agreement and a high privacy standard. Further information on information security is set out below.
What about children?
Shoppar targets adults only. If the algorithm detects that the individual is below the age of 18 it will not carry out any further interpretation.
What sorts of adverts should be displayed?
It is up to you as the data controller to decide what types of advert to place but we would urge caution against any advert that would cause individuals to feel specifically targeted or which may display anything which would cause offence or embarrassment.
What security measures are in place to protect the data?
Security training for all employees
All Shoppar employees undergo security training as part of the orientation process and receive ongoing security training throughout their Shoppar careers. Depending on their job role, additional training on specific aspects of security may be required.
Our dedicated security team
Shoppar employs security and privacy professionals, who are part of our software engineering and operations teams. This team is tasked with maintaining the company’s defense systems and developing security review processes.
Our dedicated privacy team
The Shoppar Data Science team integrate the highest level of data privacy compliance into all aspects of our software and data delivery dashboards.
An effective malware attack can lead to account compromise, data theft, and possibly additional access to a network. Shoppar takes these threats to its networks and its customers very seriously and uses a variety of methods to prevent, detect and eradicate malware.
We have a rigorous incident management process for security events that may affect the confidentiality, integrity, or availability of systems or data. If an incident occurs, the security team logs and prioritizes it according to its severity. Events that directly impact customers are assigned the highest priority. This process specifies courses of action, proce- dures for notification, escalation, mitigation, and documentation.
Securing data in transit
Data is vulnerable to unauthorized access as it travels across the Internet or within networks. For this reason, securing data in transit is a high priority for Shoppar. Shoppar uses Google servers that support strong encryption protocols such as TLS to secure the connections between customer devices and Google’s web services and APIs.
Any third party vendor that is utilised is thoroughly vetted and rigorously scrutinised to ensure they comply with the highest industry data processing and security standards.