Data Privacy Notice: Recording of video footage of track data for scientific purposes – „Digits4Rail Maps“ project

The protection of personal data is very important to Knorr-Bremse. In this privacy notice, we would like to inform you about the processing of personal data by Knorr-Bremse Systeme für Schienenfahrzeuge GmbH (hereinafter referred to as: Knorr-Bremse or Controller) when recording video footage of public traffic for scientific purposes (development of driver advisory systems for trains) and the purposes of such processing.

Legislative amendments or changes to our internal processes may require amendments to this data privacy notice from time to time. You can find the date of the latest update at the end of this notice.

§ 1 Controller's contact details

Knorr-Bremse Systeme für Schienenfahrzeuge GmbH
Moosacher Strasse 80
80809 München


§ 2 Data Protection officer's contact details

Knorr-Bremse Systeme für Schienenfahrzeuge GmbH
Data Protection Officer
Moosacher Strasse 80
80809 München


§ 3 Purpose, legal basis and scope of personal data processing

The purpose of recording video footage of public traffic is to facilitate the research and development activity conducted by Knorr-Bremse (recording of rails and infrastructure for the development of driver advisory system for rail vehicles). Video material is necessary to asses infrastructure elements. In order to develop the artificial intelligence of the system, the analysis of large volumes of video footage is needed, which will be used during the teaching, testing and validating of the system. Video footage which properly represents real traffic situations is needed for the development of the system. In recording public traffic, it can technically not be excluded that natural persons and vehicles may be recorded as well.

Knorr-Bremse hereby marks Art. 6 par. 1 lit. f) of the General Data Protection Regulation (GDPR) as the legal basis for recording the video and any associated personal data processing. The legitimate interest shall be the development of technology that serves driver advisory systems for public traffic as described above.

The video camera is being operated only for the measurements required for the research. When using the vehicle for purposes other than the purpose of the measurements, no video footage is being recorded and no video containing personal data will be captured.

§ 4 Categories of processed personal data

The track view and the traffic situations are recorded by video camera installed by Knorr-Bremse on a vehicle participating in public traffic; meanwhile the following personal data may potentially be recorded as part of the collection of video material:

  • Facial likeness and/or stature of data subjects staying and/or moving on the streets;
  • Licence plate number of trains and vehicles which are parking or moving on the streets.

§ 5 Utilisation of personal data, identification of data subject

Knorr-Bremse may use video cameras that apply precise timestamps. But even using precise timestamps, Knorr-Bremse is typically not able to identify any natural persons as Knorr-Bremse does not have any equipment or information or access to any equipment or information which can be used to link the licence plates or faces/statures that may have been recorded to specific individuals. Therefore, data subjects will in general not be identified; in fact, such identification is in no case in the interest of Knorr-Bremse and will not be pursued by any means.

§ 6 Conditions of data storage, duration of processing personal data, potential data controllers with the right of access

Knorr-Bremse will store the recorded video footages for 60 days in original form, after it evaluates and permanently deletes them. During the 60-day period following the completion of the recording video footages needed for assessing infrastructure elements and tracks are purposefully copied, which Knorr-Bremse intends to use directly for the development of the system.

§ 7 Recipients of the video footage that may include data subjects' personal data

Knorr-Bremse uses the following company as service provider for the development of driver assistance systems:

Sigma-Rail, S.L
Avda. Gregorio Peces-Barba 1
28919 Leganés, Madrid

The service provider processes the personal data only on our behalf and strictly in accordance with our instructions on the basis of contracts for order processing.

Beyond that Knorr-Bremse does not transfer the video footage or any personal data to third parties. Furthermore, the data collected will not be transferred to (and stored at) a destination outside the European Economic Area (EEA).

§ 8 Rights of data subjects relating to processing personal data

1) In general, you have the following rights towards us with regard to your personal data:

  • Right of access
  • Right to rectification or erasure and, where appropriate, restriction of processing ("blockage")
  • Right to data portability
  • Right to object to further processing

2) We acknowledge the fact that individual data subjects may wish to exercise their rights under Art. 15 to 22 GDPR (e.g. access to his/her personal data; rectification of his/her personal data; erasure or restriction of processing of his/her personal data etc.) with regard to any personal data that may be captured in the course of recording the video footage. However, it will not be possible for Knorr-Bremse to deliver on such requests as it is impossible for Knorr-Bremse to single out the specific sequences of the footage that may contain personal or personally identifiable data of the requesting data subject.

As mentioned above, Knorr-Bremse does neither have nor use any system or information that would enable Knorr-Bremse to identify any data subject that may have been recorded on the video footage. Rather, Knorr-Bremse is generally unable to identify any specific data subject or even the data related to any specific data subject.

Please note that due to the above described circumstances GDPR provides in accordance with Art. 11 par. 1 GDPR that Knorr-Bremse in its capacity as a data controller shall not be obliged to maintain, acquire or process additional information in order to identify the data subject for the sole purpose of complying with a data subject's request. Accordingly, the above-mentioned rights shall – in general – not apply (cf. Art. 11 par. 2 GDPR).

§ 9 Contact

If you have any questions with regard to this data privacy notice or would like to exercise your rights as a data subject, please contact

§ 10 Right to file a complaint with the Data Protection Authority

Knorr-Bremse takes your requests very seriously and we are committed to address any of your concerns. Nonetheless, you have the right to file a complaint with a competent data protection authority at any time.

Munich, 29.04.2020