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Questions and answers

How can you ensure of that processing is GDPR compliant?

An organization has no fixed contour. It is constantly in motion. Therefore, it is necessary to constantly keep the internal and external GDPR work up to date, highly conscious, and alive.

We have taken the following steps to ensure that we, and our customers, follow the GDPR. If you are interested to understand more about this work, click here.

1. Understanding the market need
2. Finding the solution
3. Documenting our solution
4. Analyzed the various existing anonymization methods
5. Adapted our organization to GDPR
6. Conducted multiple Risk Analysis
7. Conducted a Data Protection Impact Assessment
8. Asked other experts to challenge our beliefs
9. Been approved by the Swedish Data Protection Authority during a prior consultation

How do you actually re-identify store visitors, without saving any data?

We have spent several years researching, patenting and building a technology we call Indivd X. This method receives an image, anonymizes the image data and deletes the image data within a few milliseconds. We then use the anonymous data to produce statistics. This means that we can not uniquely re-identify any visitors but. We can, instead statistically understand re-visitation based on anonymous data.

Is the data collected to be considered as personal data?

No, the image data is anonymized and deleted within milliseconds.

What and which people are registered in the pictures?

Visitors passing by a camera in a locations where Indivd is used might be in the image data that is sent to Indivd X which anonymized and deletes the image data in within milliseconds. 

What is biometric data?

The definition of biometric according to GDPR, is “personal data derived from specific technical processing concerning the physical, physiological or behavioral characteristics of a natural person, which allows or confirms the unique identity of the natural person”.

How does Indivd process biometric data?

The Swedish Data Protection Authority has come to the conclusion during a prior consultation, completed 2020-06-26 that Indivd does not process biometric data.

Is Indivd viewed as a data processor according to GDPR?

Yes. Indivd is a data processor. Read more about our responsibilities in our Data Processing Agreement

How do you prevent that Indivd’s technology is used for something else compared to what was originally intended for?

With high protection class. The image data from the cameras is deleted within 1-2 milliseconds.

Does the processing mean that the store visitors are systematically monitored?

Yes, but only during 1-2 milliseconds until the personal data is deleted.

Is the intended image processing suitable for its purpose and legitimate interests?

Yes, according to legal experts and the Swedish Data Protection Authority.

Is the intended treatment necessary to achieve the objectives and legitimate interests?

Yes, there are no other satisfactory alternative solutions today.

Do you manage to meet the requirements that personal data not shall be collected for specified, explicit, and legitimate purpose(s) and not further processed in a manner that is incompatible with those purposes ("purpose limitation")?

Yes, the personal data (images) are used to anonymize the data in our anonymization method, where all personal data is fully anonymized and deleted within a few milliseconds.

Is the processing of images in the interests of the store visitors?

Yes. Physical stores are, by far, the most popular place for shopping and stores they will, with the help of Indivd, give the store visitors a better store experience.

In whose interests is the processing taking place and why are they important?

To our knowledge, stores currently lack the ability to efficiently collect and analyze information about their visitors in order to produce statistics and be able to customize/plan their operations.

Stores use various ways to understand their visitors. They appoint special people who manually review/monitor and take notes on what the visitors do in stores. Such a method assumes that the person conducting the survey/monitoring the visitors actually observes the same. In our view, this arrangement creates a greater risk of visitors’ personal integrity being violated as they are actually observed compared to an automatic / non-manual analysis of anonymized data.

In addition, the current order will lead to great inefficiencies, lead times in inventory management, irrelevant advertising, inefficient floor plan planning, inefficient treatment, and other similar waste of resources in retail.

Effective and efficient data analysis has great potential for increased margins and cost reductions in the pressed retail industry.

What would the impact be if Indivd couldn’t go ahead with the processing?

Lack of knowledge will through current methods lead to reduced efficiency and greater integrity infringement. This will also lead to continued wastage of resources in retail, the closing down of stores, and continued very large and increasing difficulties in competing with e-commerce.

Could individuals whose personal data it relates to be negatively impacted by the processing? If so, what is the likelihood and the severity of any such impact?

No. The risk of negative impact on data subjects is small, given the extensive technical and organizational security measures.

Would individuals reasonably expect or anticipate that the processing activities take place, or that their information is used for the connected purposes?

Information is provided in the appropriate privacy notice, read more about the controllers’ duty to inform the visitors here.  

Does the processing involve elements of automated decision making?

No, not in relation to those registered.

Are there no less intrusive Data Processing Activities that would also achieve the processing purposes and the legitimate interests?

Not to our knowledge. There are various methods used in physical retail today which all are seen as more intrusive and less accurate.

Is the access to the Personal Data, affected by the intended Data Processing Activity, limited to those individuals with a need to Process the Personal Data to achieve the processing purposes and the legitimate interests?

The process is automatic and unsupervised. No person has access to the personal data and the images have a high degree of protection.

Is the processing lawful in accordance with the legitimate interests?

Yes. That is the understanding of the Swedish Data Protection Authority and the legal experts that have audited our technology.

If I asked you to give to me my data, would that be possible?

The anonymized data is not personal data and cannot be linked to natural persons. This means that we do not have any data about you. We have no data which directly or indirectly can be associated to you and we can not give you data we do not have. The images from the surveillance cameras can be requested according to customary routines to manage the rights of registered persons.

What is your opinion of the use of facial recognition in schools?

Indivd is founded on an idea of privacy-driven technology where human rights are at the core of the development. That is why we consider the potential abuse of our fundamental human rights that traditional facial recognition provides the opportunities is too big of a risk. 

In a recent press release it was claimed that your product for retail environments is anonymous. However, many of us do not understand that position as facial recognition by definition is designed to “recognise" an individual (to single them out) and as such any such data is considered as personal data under the GDPR (even if it is just a biometric hash) - what is your response to this?

We do not work with traditional facial recognition. We have created a new type of facial anonymization to prove that there are better ways to use these types of technologies without abusing persons’ privacy. This new technology we call Anonymous Facial Recognition, read more about how this works at “How do you actually re-identify store visitors, without saving any data?

How to you work with integrity and GDPR in general?

Integrity, privacy, human rights, and GDPR is the foundation on which we build Indivd and our new technology. We work with these core values in various ways. 


  1. We work for better awareness of the big privacy issues by participating in the debate.
  2. We create new services and innovations that raise the overall privacy in society.
  3. We actively influence policies where it matters and support privacy-initiatives.