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Apple recordings for map services

Since Monday 29.07.2019, vehicles of the US company Apple equipped with cameras and sensors have been driving through Germany. The only thing that is clear is that Apple plans to carry out recordings for map services. What exactly is to be photographed is not known. According to information from Apple, the light-coloured small cars with a fixed camera on the roof will start taking pictures first in Munich, Stuttgart and Frankfurt.

In what way does Apple have permission to record?

According to the Bavarian State Office for Data Protection (BayLDA), Apple presented a data protection concept for the collection of data in spring 2019. According to the BayLDA, the data protection concept is conclusive.

What is the purpose of the recordings?

According to Apple, the first step is to improve the maps for navigation tips. The data will not be passed on to third parties. The recordings were increasingly associated in the media with the so-called "look-around" service. The concept of Look-Around is comparable to Google Streetview and is supposed to display entire streets in 3D format. According to Apple, however, this service is not planned for Germany. Should the currently created images be used for Look-Around after all, a new data protection concept must be presented.

What happens with the data?

The fact that Apple has not made it clear exactly which content is to be published is causing a stir. So it makes a decisive difference whether the focus of the photos is on European sights in particular or private properties. Furthermore, Apple reserves the right to store the data for up to 36 months. Although the company promises to blur faces or license plates, there is no guarantee that this will happen in 100 percent of cases. The topic is currently very controversial in Germany. The data protection commissioner of Schleswig-Holstein Marit Hansen says:

"Not everyone has consented to photos of private property that can be accessed for years and where it is possible to see that one has not perfectly maintained one's front garden, that expensive cars are parked in front of the house or where burglars could easily get in."

Source: https://www.ndr.de/nachrichten/schleswig-holstein/Apple-Kamera-Fahrten-Jetzt-schon-Widerspruch-einlegen,applelookaround100.htm

What can you do?

The General Data Protection Regulation focuses on the protection personal data. Data subjects therefore have a comprehensive right to information about the nature and purpose of the recordings by Apple. If you do not agree with the processing of your personal data, you can already lodge an objection. You can also lodge an objection with the competent data protection authority.

External Data Protection Officer

You are welcome to contact us as external data protection officer (DPO) order. We also offer individual consulting services as well as audits and will be happy to provide you with a non-binding offer. You can find more information about our external data protection officers on our website.

Which data protection authority in Germany can I file a complaint to?

According to the Bavarian State Office for Data Protection, complaints about Apple's camera recordings can be made directly via the following Online form be submitted to the BayLDA.

How can I lodge an appeal myself?

You have several possibilities to appeal:

  • Opposition by e-mail: Use the e-mail address MapsImageCollection@apple.com. On the website maps.apple.com/imagecollection you will find more detailed information about the recordings.
  • Contradiction about the "Report Problem" feature of Apple Maps: Within Apple's "Maps" service, users can "report a problem", but only to the extent that users provide a specific point of view.
  • Objection to the Apple Privacy Form: The general form on the subject of data protection at www.apple.com/de/privacy/contact can also be used for oppositions.
  • Opposition by letter post: Please send the notice of opposition to the following address
    • Apple Distribution International
      data protection officer
      Hollyhill Industrial Estate
      Cork
      Ireland

When exactly in which regions are Apple camera drives made?

Apple has published an official document with the exact times. The document can be accessed via the following link: https://maps.apple.com/imagecollection/detailed-driving-data/de/de/detailed-driving-data.pdf

Prof. Dr. Andre Döring

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