Wi-Fi sensors and your privacy

Update 29 April 2021: On 29 April 2021, the Dutch Data Protection Authority fined a council in the Netherlands for Wi-Fi tracking. Because of this, Breda council decided not to use the Wi-Fi sensors installed in the city centre until further notice.

Map with Wi-Fi sensors

The map shows where Breda Council has installed Wi-Fi sensors in public areas within the city centre. This map will be updated regularly. The council also places signs in the areas where Wi-Fi tracking is active. Breda Council wishes to be transparent about the use of Wi-Fi tracking and therefore ensures that visitors to these areas are aware where we collect data. The map shows the locations of the Wi-Fi points.

Times during which data are recorded

• Monday to Wednesday and Sunday: from 10.00 - 20.00 hours
• Thursday (due to late-night shopping): 10.00 - 22.00 hours
• Friday, Saturday and Sunday: from 10.00 to 5.00 hours
• Public holidays: 10.00 to 5.00 hours
• Event days: from 10.00 to 5.00 hours.

Privacy statement Wi-Fi sensors

This is Breda Council's specific privacy statement about the processing of personal data by Wi-Fi sensors. In this statement you will find more information about Wi-Fi tracking, why we use it and exactly what data we record and other important information.

Introduction

Breda Council wishes to improve the safety and quality of life within the city centre. A healthy physical environment for its citizens. One way to achieve this is by measuring visitor numbers in certain parts of the city centre. This allows the council to manage crowds. By measuring and analysing data about visitor numbers, the council can decide whether an unsafe or unpleasant situation could potentially arise due to a high number of visitors. Based on the measured and analysed information, the council can take measures to improve the safety and quality of life within the city centre. Breda Council also gains a better understanding of the use of the city centre and can adjust management and services accordingly. This information can also be used to improve the layout of the public spaces in the longer term. Data is measured using 'Wi-Fi tracking’.

The purpose of Wi-Fi sensors

The main purpose of measuring visitor numbers through the use of Wi-Fi tracking is:

• To collect information about numbers, densities and pedestrian flow to enable smarter measures to be taken to manage crowds. As a result, the city remains comfortable, accessible and safe in the short, medium and long-term, and this improves the quality of life. In the longer term, the layout of the public spaces will be improved.

This main purpose has 5 specific sub-purposes:

• To prevent and manage unsafe situations (safety).
• Good visitor accessibility of public places and services and good traffic flow in a larger area around the busy locations (accessibility and traffic flow).
• High-quality public areas in which visitors feel welcome, safe and comfortable (quality and comfort).
• Improved layout of the public spaces in the longer term.
• Provide businesses in the city centre with a greater understanding of visitor flows. To this end, Breda Council shares the aggregated data (no personal data) with businesses.

Grounds

Breda Council processes these personal data based on the legal grounds ‘public law task’. The personal data are required to make sure there are safe (uphold public order and safety), accessible and comfortable public areas (healthy physical environment) for all citizens (visitors to the city centre of Breda).

The Wi-Fi sensors collect a 'MAC address' and location data. A MAC address is a unique identification number connected to a device, such as a mobile phone, tablet or computer.
Breda Council considers the MAC address to be personal data within the meaning of the GDPR (AVG). The MAC address of a smartphone is considered to be 'indirect personal data' because it provides information about the user indirectly.

Protection of personal data

Breda Council protects the MAC addresses from unauthorised use, both technically and organisationally. The MAC address (and the IP address) are immediately pseudonymised (i.e. illegible). This reduces the risks for visitors. This contributes to Breda Council's obligation to protect the data properly.

This means there is just a ‘dot’ on the screen and the original MAC address cannot be discovered. It is impossible to see who had a device with that MAC address.

No transfer to other parties

The personal data are not shared with other organisations (outside the European Economic Area).

Retention period

There is no (legal) retention period in relation to the processing of MAC addresses. For that reason, in line with the advice issued by the Dutch Data Protection Authority, Breda Council applies the principle that the data are not saved once these have been pseudonymised.

Access

It is not possible to access the personal data. This is because the MAC address is immediately and irreversibly pseudonymised on the Wi-Fi sensor. This means there is just a ‘dot’ on the screen and the original MAC address cannot be discovered and it is no longer possible to discover the original MAC address, let alone see who had a device with that MAC address.

Breda Council uses the anonymous data (the 'dots') to check how busy an area is. From those dots, the council is able to see how busy it is, the walking flows and the walking routes, and where people remain for longer.
If you do not want us to process your data, you could always turn off the Wi-Fi signal on your mobile device (telephone, laptop, etc.)  The sensor will then be unable to collect a MAC address.