Visitor Information Requirements

Note: This document is for general information purposes only and should not be considered legal advice. For legal advice, please consult a lawyer.

This guideline outlines how to fulfil the legal obligation to inform visitors about data collection when using people counting technology, such as 2D or 3D cameras. The requirements are based on the GDPR, including guidance from the European Data Protection Board (EDPB) and the Swedish Authority for Privacy Protection (IMY).

This obligation applies universally to all systems that process personal data for people counting, regardless of technology provider, setup, or where data is processed. It stems from Articles 12 and 13 of the GDPR and the transparency principle in Article 5(1)(a). Even if data is anonymized, deleted immediately, or processed on-premises, visitors still have the right to be informed.

Information must be provided through a layered approach: signage as the first layer, detailed information as the second.

This article contains the following topics:

• The two-layer approach
• First layer: sign requirements
• Second layer: detailed information
• Processing purposes (copy-ready)
• Contact

The two-layer approach

First layer: sign requirements

Placement checklist:

• ☐ Placed at eye level
• ☐ At every entrance
• ☐ Visible before the visitor enters the monitored area

Content checklist — the sign must include:

• ☐ Identity and contact details of the data controller and any representatives
• ☐ Purpose of processing (e.g., analyzing and categorizing visitors)
• ☐ Visitors' rights: access, objection, deletion of data
• ☐ Any special processing details (e.g., storage outside the EU, long storage times, real-time surveillance, sound recording)
• ☐ Reference to the second layer (QR code, web link, or brochure)

Example signs:

Second layer: detailed information

Content checklist — must include all details required by Article 13 GDPR.

Access checklist:

• ☐ Digital access: web page or QR code
• ☐ Non-digital access: printed brochure or phone number
• ☐ Accessible without entering the monitored area
• ☐ Privacy policy updated to reflect the processing
• ☐ First layer sign clearly references this second layer

Optional: A printed brochure or poster available at information desks, reception, or checkout can serve as the second layer or supplement it.

Processing purposes (copy-ready)

These purposes have been assessed within the framework of the prior consultation with the Swedish Data Protection Authority. We therefore presuppose that these are correct. They can be used directly in your privacy notice or signage.

1. Understand how different objects in the store environment (shelves, aisles, furnishings, entrance, signage, lightings, etc.) attract interest (attention, interacts with, leads to conversion) from visitors to be able to make changes that lead to the store environment becoming more efficient and relevant to all visitors.
2. Understand where and when queues are formed (e.g. checkouts, dressing rooms, toilets, customer service counters) in order to be able to make changes that lead to a streamlining of store operations and minimization of queue formations.
3. Understand how visitor flows take place in order to be able to make changes that lead to a streamlining of customer flows in the store.
4. Streamline internal operations by understanding visitor flows and then adapting staffing at different locations / departments in the store.
5. Understand how visitors navigate the store's planned visitor journey turns (i.e. which paths visitors walk in the store) in order to implement changes that lead to increased efficiency and relevance of the visitor journey.
6. Enable clearer comparisons and thereby understand differences between different stores, e.g. the impact of our store environments, queuing, visitor flows, the attraction of objects, visitors' navigation in the stores' planned visitor journeys, etc. to learn about the differences and make changes that lead to a streamlining of our organization's overall operations. We could, for example, make two separate investments in two stores with similar conditions. In one store we invest in education for the staff, and in the other store we invest in a new store interior. If the results of such a study would show that it is more favorable to provide our staff with more education, it could lead us to restructure our investments and increase the efficiency of our organization's overall operations.
7. Enable clearer comparisons and thereby understand differences between different stores, e.g. the impact of our store environments, queuing, visitor flows, the attraction of objects, visitors' navigation in the stores' planned customer turns, etc. to streamline / adapt planned establishments, including identifying new cities / areas for establishment.
8. Enable clearer comparisons and thereby understand differences between our stores and other stores over time, for example regarding the impact of store environments, the attraction of objects, queuing, visitor flows, visitors' navigation in the stores, planned visitor journeys, etc. to get and try new ideas and offers, e.g. by introducing a yoga studio or running club to increase innovation and strengthen our competitiveness. For example, insights that a large proportion of visitors are attracted to (pay attention to, interact with) sports products could lead us to temporarily try to launch a running club in the store. A recurring activity in the store could lead to visitors gathering to run and discuss running in order to strengthen the store's brand towards that target group. With an increased understanding of differences, the attractiveness of objects, visitor flows, etc. could lead to an increased understanding about the investment's profitability if (i) more visitors visit us (ii) new target groups visit us (iii) it leads to increased attractiveness for other products (iii) we have an increased frequency of visits and an increased attractiveness in relation to benchmark data, which in itself leads to increased competitiveness.

Contact

For questions or concerns about visitor information, contact us at privacy@indivd.com.