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Privacy notice on data processing during videoconferences

Privacy notice on data processing during videoconferences

last updated on 24.6.24

This information provides information on the processing of personal data by the controller, Veoneer US Safety Systems, LLC, acting on its own behalf and as agent for each of its Company Affiliate (hereinafter "Veoneer") in relation to video conferencing.

What data is processed

Type of personal data How is the personal data obtained?
Registration and contact data, e.g., name, e-mail address, telephone number. We have received this data from you directly before the start of participation in the video conference or receive it when you participate in the videoconference.
Communication data, e.g., visual as well as vocal contributions and input in chats and shared screen contents and automatic transcriptions.  This data could be collected directly from you during participation in the videoconference.
Usage data and metadata (e.g., device information, IP addresses). This data is collected directly and automatically from you during your participation in the videoconference.


Retention period

We retain your data for as long as is necessary for the purpose for which the data was collected. When we determine that there is no longer a need or requirement to retain your data, that data will no longer be processed and will be deleted in accordance with applicable laws or internal policies. 

By default, the retention period for meeting recordings in Microsoft Teams is configured to last 60 days. Upon reaching this duration, any recording will be subject to expiration and subsequent automatic deletion. 

For transcriptions instead the default retention period is 120 days. Upon expiration they will be automatically deleted as well. 

 

Purposes of data processing

Personal data

We process your personal data only as permitted by law. The table below lists the purposes and legal bases for which we process your personal data.

Purpose of the data processing Justification/legal basis for the processing
Recording of the videoconference involving exclusively Veoneer employees: Personal data collected during the videoconference is made for the purposes of documenting organizational decisions, recording as a memory aid, creating training materials.   The company legitimate interest (creation of training and educational materials, staff induction phase, etc.) and the explicit consent of each videoconference participant (i.e., actively unmuting the microphone, turning on the camera, or sharing the screen after the recording consent banner showed up). 
Recording of the videoconference involving external parties: Personal data collected during the videoconference is made for the purposes of documenting organisational decisions, recording as a memory aid, creating training materials.   The explicit consent of the external party (i.e., actively unmuting the microphone, turning on the camera, or sharing the screen after the recording consent banner showed up). And, in a few cases, the overriding company legitimate interest (creation of training and educational materials, staff induction phase, efficient and secure communication with our communication partners).
Transcription of voice inputs: Personal data collected during the videoconference is made for the purposes of documenting organisational decisions, recording as a memory aid, creating training materials.   The company legitimate interest (creation of training and educational materials, staff induction phase) and the consent of each videoconference participant (i.e., staying in the meeting and speaking after the transcription consent banner showed up).
Usage data and metadata for security purposes, service optimisation.     Legitimate interest (security purposes, service optimisation, efficient and secure communication with our communication partners).

The disclosure of your personal data is not legally or contractually required, but it plays an important role for a full and effective engagement in videoconferences. While it is entirely your choice to provide this information, please note that not doing so may limit your ability to participate fully in the videoconference. 
In extreme cases, if you refuse to share personal information, no alternative solution is identified, and Veoneer has a competing legitimate interest that outweighs your rights as a data subject, you might not be able to participate in the videoconference. 

Special categories of personal data

We do not process any special categories of personal data, in particular no health data, unless you actively communicate this during the video conference.

 

Recipients and authorised persons

Recipients or category of recipients  Purpose of data processing
Microsoft Teams  Technical implementation of the videoconference (hosting)

The personal data might be transferred to or accessed from a third country but always within the Veoneer organization.
 

Automated decision making

There is currently no automated decision making.  
 

Your rights

You may exercise your rights of access, rectification or erasure or to restrict processing or exercise your right to object to processing and the right to data portability at any time. You have the option of contacting our HR department in person, by email or by letter. Furthermore, you have the right to contact the data protection supervisory authority in the event of complaints.

For any doubts or concern regarding this document, you can contact our data protection officer at [email protected]

Consent Request to Participants for Audio and Video Recording, Web Streaming During Meetings, Events, Conferences, and Transcriptions, etc.
This privacy notice has been updated to reflect the new methods by which we seek consent for recording and transcribing videoconferences. Consent can be requested during a videoconference in two distinct scenarios:

Recording Consent
A consent banner will be displayed to all participants, which includes a link to this privacy notice. Participants must actively unmute their microphone, turn on their camera, or share their screen to provide consent for recording. These actions are all considered an express statement of consent. If you give consent in this way, you agree to the collection and processing of your personal data, as well as to the internal use of the audio and video recordings by Veoneer. If any participant does not give consent, the recording will not be initiated. 

Transcription Consent
A separate consent banner will appear for transcription consent, also containing a link to this privacy notice. Transcription will commence immediately upon the display of the banner. Participants who do not consent to the transcription have the option to remain into the meeting without speaking or find an alternative solution together with the meeting organizer. 
Please note that participants’ actions in response to the consent banners are critical for the activation of recording and transcription features. The refusal of any participant to consent to recording will prevent the recording feature from being enabled. Conversely, for transcription, the service will be activated regardless, and non-consenting participants are advised to participate silently or find an alternative solution together with the meeting organizer.

Withdrawal of Consent
You can freely withdraw your consent at any time. In that case, all processing operations that were based on your consent and took place before the withdrawal of consent remain valid. If you change your mind and no longer agree with your image or voice being recorded and published, or you no longer agree with the automatic transcription of your voice, you can independently stop the recording or transcription (in MS Teams meeting select “More”, then “Record and transcribe”, then “Stop recording” or “Stop transcription”). You can also communicate your intention to withdraw your consent to the meeting organizer (verbally, via meeting chat or otherwise). In this case, the organizer will either stop the recording or transcription of the meeting or, if these options are not practicable, will try to find an alternative solution that respects your rights while still allowing the meeting to proceed in a way that meets the company’s needs.
If you do not belong to this organization, you will not be able to stop the recording or the transcriptions by yourself. Please communicate your intention to withdraw consent directly to the meeting organizer verbally, via meeting chat, or via email, as you prefer.


Please confirm to the meeting organizer that you read and understood the conditions of this consent request.

Your Rights 
In relation to the personal data processing activities in videoconferences described above, besides the right to withdraw consent detailed in the previous section, you may exercise your rights of access, rectification or erasure, restriction of processing, objection to processing, and data portability at any time. 


To exercise any of these rights, please contact either the meeting organizer or the Veoneer Safety Systems Data Protection Officer at the following address: [email protected] .  
You also have the option of contacting our HR department in person, by email, or by letter. Furthermore, you have the right to contact the data protection supervisory authority in the event of complaints. 


For any doubts or concerns regarding this document, you can contact the Veoneer Safety Systems Data Protection Officer.

Meeting Organizer in Microsoft Teams
In the context of Microsoft Teams, the “meeting organizer” is the individual who schedules and sets up the meeting within the platform. The organizer also has control over certain features during the meeting, such as starting and stopping recording or transcription, muting participants, and managing participant permissions.
Once you start a meeting recording or transcription, you will be invested with a series of privacy obligations. 


Such privacy obligations include, but are not limited to, collecting valid and informed consent, properly handling withdrawal of consent, supporting the attendees in the exercise of their other privacy rights, respecting the storage limitation principle, and considering the privacy rights of the attendees before sharing, downloading, editing, and deleting the recording or transcription of the videoconference.


If you are not the meeting organizer but have started the recording or transcription, the responsibilities outlined in this document will apply to you as well. You will be considered in the same role as the meeting organizer, along with the actual meeting organizer. 

Effectiveness and updates
This privacy notice is effective as of the date stated at the top of this notice. Please note that we may update this privacy notice from time to time as necessary. The terms of this privacy notice will govern the use of any information collected while it is in place. We encourage you to review this privacy notice regularly to ensure you are aware of any changes. 
 

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