Mapping

Remember that there are special requirements that apply whenever people
whose images you collected can be identified. Keep in mind that sometimes it
may be possible to identify people also from the context – location, house
numbers, car registration numbers, time of day, etc.

Lawfulness, fairness, transparency:  Your collection
and processing of personal data must be lawful, based on one of the options
laid down by EU law. It must be fair, meaning that it must not cause any harm
to the individuals. It must also be transparent – people have to know if their
images have been captured, by whom and why. You must not do anything unlawful
with the data.

Purpose limitation: People have the right to know exactly
for what purpose their data is collected and, once you inform them of the
reason (mapping), you cannot use their data for a different incompatible
purpose (e.g. profiling of the neighbourhood for marketing purposes) without
informing them again and ensuring your actions are lawful (see above).

Data minimisation:  You should collect as little
personal data as possible to achieve your goals – the mapping of the area.
Only collect what is necessary, directly related to your purpose and/or
unavoidable.

Storage limitation: You should not keep the footage of
people in a manner that would allow their identification for longer than
necessary for your planned purpose.

Integrity and confidentiality: Where you have footage of
identifiable people, you should make sure that that data is stored in a secure
and protected manner. Unauthorized access must be prevented.

Accountability: Remember that if you collect personal data
and can choose what to do with it, you will be accountable if you don’t follow
any of these principles.

TIPS - If you think someone has a reasonable expectation
of privacy, don’t violate that privacy by taking pictures, video, or
otherwise gathering personal data, especially by targeting a specific
person.

TIPS - Engage in a public information campaign. Consider
the use of advertisements, signs, leaflets and social media announcements
that provide information about what the drone is doing, when it will be
operating, what it may record, and what the footage will be used for. Don’t
forget to include your contact information as well, so individuals could
turn to you if they have any questions or requests. If someone does not wish
to be filmed, you should comply with their wish.

TIPS – Only collect and store data relevant for mapping.
Collect the minimum amount of data necessary in relation to your legitimate
course. Consider flying at a lower altitude above the space you wish to map
to ensure less background data is collected. This also ensures that
individuals are more aware of the drone and promotes transparency.

TIPS - Individuals recorded should have a right to
access the material where they can be identified and should be enabled to
request the data controller to delete that material. You should inform them
of that right.

TIPS - Do not share data on identifiable persons with
third parties without the agreement of the people in the images or without a
legal obligation requiring you to do so.

TIPS – Consider taking anonymising steps whenever and as
soon as possible, such as blurring, to minimise the amount of personal data
collected. E.g., blur the images of people inadvertently caught on the
footage, as well as all house numbers and car registration and plate
numbers.

TIPS - Store any personal data collected in a secure
manner, and ensure that it is not stored longer than necessary for your
planned purpose.

TIPS – Be aware who the data controller and the data
processor is in this case, especially if you are carrying out this activity
together with another company. Remember that data controllers and data
processors are subject to various legal obligations in the EU.