Data processing in the context of test drives

ISUZU Motors Germany strives for high quality standards in the development of vehicles and vehicle systems. We apply the same high standards to the handling of your personal data.

In order to improve the safety and driving comfort of new vehicles, ISUZU is working on the development of driver assistance systems. For this purpose, we drive with appropriately marked test vehicles on test sites and public roads and record the data of the vehicle and the environment. This also includes videos of the vehicle's surroundings.

1. Responsible body for data processing

ISUZU MOTORS Germany GmbH, based in 65462 Ginsheim-Gustavsburg, registered under Darmstadt HRB 53969, is the controller within the meaning of the EU General Data Protection Regulation ("GDPR") for the processing of personal data related to the video and audio recordings for the development of driver assistance systems.
For enquiries, please contact
Im Weiherfeld 2
65462 Ginsheim-Gustavsburg
You can also reach our data protection officer at

2. What data is processed and for what purpose?

Many vehicles on our roads already have cameras and sensors (such as radar, ultrasonic or GPS) to detect objects in the environment. As a result, they are able to recognize, for example, cars, motorcycles, people, lane markings or traffic signs and support the driver with assistance functions such as emergency braking assistants or lane departure warnings.

The marked test vehicles are equipped with similar technology. In contrast to production vehicles, which usually do not store videos, video and audio data are stored in our tests on public roads for the analysis and further development of the assistance systems.

When evaluating the videos, the traffic objects are categorized so that the vehicle can include the different characteristics of the road users in its calculations. Normally, it is not possible to identify individual persons, as the recording only takes place briefly in passing. However, when driving slowly or at a standstill (e.g. at a traffic light, in a traffic jam or at pedestrian crossings), it cannot be ruled out that persons are recognizable and thus personal data within the meaning of the GDPR is recorded.

During the evaluation of the videos, the traffic objects are categorized so that the vehicle can take into account the different characteristics of the traffic objects. The recorded data is used exclusively for the further development and improvement of road safety or for the further development of the functionality of driver assistance systems or comfort functions of new vehicles.

The following example shows an image of our cameras with the classified objects (red = vehicle, yellow = pedestrian, blue = cyclist).

3. Legal basis for the processing of personal data

The legal basis for the collection and processing of personal data for the development of driver assistance systems is the "legitimate interest" of the controller according to Art. 6 para. 1 lit. f GDPR, which consists in the research, development and testing of vehicle systems.

ISUZU has not only an interest, but also a duty to carefully develop and test vehicle systems. The stored data is therefore also used as evidence to the approval authorities in connection with the homologation (type approval) of the vehicles.

4. How long will personal data be stored?

Personal data will only be stored for as long as is necessary for the purposes mentioned above or to comply with legal obligations.

5. To whom will the data be disclosed

The development of driver assistance systems is highly complex and can only be achieved in cooperation with other companies. In general, the data is shown in the context of research and development as well as parameterization and validation in connection with driver assistance systems. For this purpose, Isuzu Motors Germany GmbH is commissioned on a project-by-project basis by the parent company Isuzu Motors Limited, Yokohama, Japan. Accordingly, the data are made available to the parent company's data. The adequate level of data protection is in place, as an adequacy decision pursuant to Art. 45 para. 1 GDPR.

If necessary, we share the data with internal and external cooperation partners, suppliers (e.g. sensor manufacturers) and service providers (e.g. for data processing) in compliance with the legal provisions.

6. Marking of the test vehicles

Our test vehicles are marked with the following or similar stickers:

7. Rights of data subjects

In accordance with Art. 15ff. GDPR, persons who have been recorded by our recording devices may claim the following rights toward ISUZU at the responsible body as specified under No. 1:

  • right to be informed
  • right to rectification
  • right to erasure
  • right to restriction of processing
  • right to data portability
  • right to object

Since no road users are identified during data processing, we cannot trace whether a person has been recorded at all without further information. In order to determine whether you are affected, we therefore need the exact location and time as well as other personal characteristics with which you can be clearly identified on our videos.

ISUZU Motors Germany will take great care to address your concerns. If you believe that your rights have not been sufficiently taken into account, you have the right to lodge a complaint with the competent data protection authority.

This Privacy Policy is valid and has the status of July 2024

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