The HeadCounter device by Blimp is privacy compliant. What does this mean?

Head-Counter is a device produced and sold by Blimp with the aim of providing its customers information on the flow and density of people entering its field of view. The device falls within the broader category of Digital Signage devices. Head-Counter uses face detection algorithms to carry out its measurements. These algorithms refer to technologies that detect the presence of a human face in an image, without identifying it. The image analysis and acquisition system developed by Blimp can take photographs in a certain area. These are then processed by a calculation unit inside the measurement device, which extracts the information of interest.

Aggregation and anonymization

Aggregation and anonymization operations allow to extrapolate the audience information from the photographs, without any identifying element. Information includes: the number of faces, the number of pedestrians or vehicles in an area, the number of individuals belonging to a specific gender (for example: 500 men and 200 women). The acquisition has a limited duration and takes place at the very moment in which the photograph is acquired. No personal data remains on the hard drive and no data is transferred outside the measurement device. The extrapolated data remain exclusively in the volatile memory (RAM) of the Main Board for the time necessary for their processing, maximum 500 milliseconds. Afterwards, they are immediately eliminated. It is not possible to access the Main Board from the outside or remotely: during standard use, communication is one-way. Access to the Main Board is only possible during the configuration phase, under the explicit request of the customer and through specific commands.

A system to protect privacy

The Italian Data Protection Authority clarifies that, if the system uses mere face detection algorithms, if the methods of deleting the images are almost immediate and no personal data remains permanently stored in the system, the processing of the data is compliant with the principles on the protection of personal data (Provision no. 551 of 21 December 2017 and Provision no .13 of 21 January 2016). To protect the Data Subjects, Blimp also ensures the adoption of the necessary technical and organizational measures in the field of data security to avoid accidents, data leaks and data breaches. It prevents access to data for non-professionals and ensures that its operators are properly authorized and trained on all the necessary steps needed to process of personal data. Furthermore, Blimp constantly monitors its equipment through an audit system and collection of periodic logs, aimed at avoiding tampering and malfunctions. Finally, in the areas where its acquisition systems are present, Blimp displays a synthetic Privacy Policy on the processing of personal data, linked to an more complete and extensive Privacy Policy via link or QR code, as required by the Italian Data Protection Authority.

Privacy by Design – operation scheme