Data protection impact assessment
For an authority putting a shore node or drive units to work. Monitoring a public place is high-risk processing, so this is done before the first node goes live.
What this is
A starting point, not a finished assessment. The facts about how Sensolytica works are filled in. The judgements are your authority's: your data protection officer decides them and signs the assessment off.
Draft as at 12 October 2026. Not legal advice, and not a substitute for your own. It does not discharge your duties under UK GDPR or the Data Protection Act 2018. Have it reviewed by a professional adviser.
- Filled in by Sensolytica
- 22 facts about the product, as built
- For your authority to judge
- 29 answers only you can give
Who is completing this
The authority is the controller. Sensolytica is a processor acting on its instructions.
- Authority
- Completed by, name and role
- Data protection officer
- Date started
Is a DPIA required?
Our reading of UK GDPR Article 35 and the ICO's list. Your DPO confirms it.
- Systematic monitoring of a publicly accessible place, using automated recognition. That alone usually requires a DPIA.
- Vessel names and registration marks are personal data when they can be linked to a person, which they often can.
- Evidence may be used in enforcement, which affects people's rights.
- Your conclusion, and who reached it
The processing
Your deployment, in your own words.
- Sites and zones
- Number of shore nodes and drive units
- Hours of operation
- Why this location
What is collected
What the units record, as built.
| Data | Held where | Kept for |
|---|---|---|
| A clip of about 10 seconds and up to six key frames | Encrypted object storage, UK | Your retention setting, 24 months by default |
| Radar speed and a vision estimate per object | Database, UK region | With the capture |
| Vessel name or registration mark, when legible | Database, UK region | Anonymised after 30 days for passes within the limit |
| Drive unit readings from the outboard's motor controller: rpm, current, voltage, temperatures, faults, run time, position with GPS accuracy | Database, UK region | With the record |
| Who set each verdict, and why | Audit trail | 7 years |
What is not collected
- No facial recognition and no biometric identification of people.
- No audio.
- No continuous recording: a shore node records only when something moves through the zone.
- No linking to any other register by Sensolytica. If your authority does that, it belongs in this assessment as your processing.
Lawful basis
For a public authority this is normally public task, not consent.
- Lawful basis relied on
- The statutory power you rely on
- Article 9 condition, if any
Necessity and proportionality
What else you tried, and why this is in proportion.
- Alternatives considered
- Why this is proportionate
- How people are told: signage, your website
- How someone objects or asks for their data
Risks
Three risks that apply to every deployment are seeded with what the product does about them. You score them and add your own.
| Risk | Measure in the product | Likelihood | Severity | Residual |
|---|---|---|---|---|
| A vessel is wrongly identified and someone is accused unfairly | A person confirms every breach against the frames before it counts; verdicts can be changed and every change is logged | |||
| Evidence is kept longer than needed | Retention runs on a schedule, not by hand | |||
| Someone sees another organisation's data | Every row is scoped to one organisation in the database; staff access needs a reason and is logged | |||
| Add a risk of your own | ||||
Measures already in place
- Data stays in the United Kingdom, encrypted at rest.
- Named accounts with roles; two-factor sign-in available to everyone.
- Every reading sealed with SHA-256 and chained when it lands.
- The on-site agent writes advisory notes only. It never sets a verdict.
Outcome and sign-off
Article 36 requires prior consultation with the ICO only if a high risk remains after the measures.
- Residual risk: low, medium or high
- ICO consultation needed?
- Approved by
- Date, and next review date