Privacy & Data Governance Levels (V9 Enterprise)
Why this exists
In most people-counting systems, “privacy” is described as a static product claim.
In V9 Enterprise, privacy is a governance decision.
We deliberately separate:
- What the platform is capable of
- What the customer chooses to enable
- What is technically enforced and auditable
This section introduces the Privacy & GDPR Compliance Levels—a structured, selectable framework that allows enterprise customers to negotiate, document, enforce, and audit their chosen privacy posture over time.
This is designed for:
- CIOs / Heads of IT
- Security & Compliance teams
- DPOs and enterprise architects
- Executive stakeholders signing off DPIAs and procurement
Design principles (executive summary)
-
Privacy by architecture, not promises
Enforcement is built into system domains, not left to operational discipline. -
Selectable but non-bypassable
Customers can choose a level—but once selected, it is technically enforced across all modules. -
Audit-first, not incident-driven
Every privacy-relevant change is logged, immutable, and reviewable. -
GDPR-aware, not GDPR-dependent
Higher levels are explicitly designed to be outside GDPR scope by construction.
The Five Privacy Levels (reversed model)
In V9, Level 5 is the safest, and Level 1 is the most permissive.
This inversion is intentional and signals risk clearly at executive level.
Level 5 – Fully Anonymous (GDPR-Exempt by Design)
Intended for:
Airports, public infrastructure, government buildings, privacy-critical retail, legal-risk-averse enterprises.
What this means:
- No personal data is collected, processed, or stored
- No identifiers, no signals, no re-identification vectors
- Data cannot be combined with any external dataset to identify individuals
Allowed
- Aggregate people counts
- Directional flows
- Time-based totals (hour/day/week)
- Occupancy thresholds
Not allowed
- Wi-Fi
- Bluetooth
- Device fingerprinting
- Image retention
- Path reconstruction
- Any identifier persistence
Compliance posture
- Designed to be outside GDPR scope
- No DPIA required in most jurisdictions
- Minimal compliance burden
Level 4 – Anonymous with Ephemeral Intelligence (GDPR-Exempt)
Intended for:
Enterprises needing operational insight without privacy exposure.
What this means:
- Short-lived, non-persistent signals may exist in memory
- No storage of identifiers
- No cross-time or cross-location linkage
Allowed
- Real-time queue length
- Live occupancy alerts
- Temporary path smoothing (non-persistent)
- On-device only processing
Not allowed
- Persistent IDs
- Historical path replay
- Wi-Fi / BLE storage
- Cross-store or cross-day linkage
Compliance posture
- Still GDPR-exempt by architecture
- Signals are mathematically non-recoverable once expired
Level 3 – Pseudonymous Analytics (GDPR-Scoped)
Intended for:
Retail analytics teams balancing insight and compliance.
What this means:
- Pseudonymous identifiers exist
- Identifiers are rotated, salted, and non-human-readable
- No direct identification, but GDPR applies
Allowed
- Path analytics
- Dwell time
- Zone transitions
- Limited retention windows
Restricted
- No raw image access
- No long-term identifier reuse
- No external data joins
Compliance posture
- GDPR applies
- DPIA typically required
- Strong internal controls needed
Level 2 – Enhanced Signals (GDPR-Scoped, Higher Risk)
Intended for:
Advanced analytics, R&D pilots, controlled environments.
What this means:
- Additional sensing modalities may be enabled
- Stronger governance required
Allowed
- Wi-Fi (hashed, salted)
- Bluetooth (configurable)
- Extended retention (policy-bound)
Requirements
- Explicit customer approval
- Internal access control
- Regular audits
Level 1 – Maximum Capability (Strict Governance Required)
Intended for:
Very specific, legally reviewed deployments.
What this means:
- Full platform capability is technically available
- Strongest compliance obligations
Allowed
- All sensing modules (subject to law)
- Longitudinal analysis
Non-negotiable
- Formal DPIA
- Legal sign-off
- Contractual safeguards
- Continuous audit readiness
Enforcement model (this is the differentiator)
Privacy levels are not labels. They are enforced through architecture.
Central Privacy Registry (separate domain)
- One registry per company
- All entities inherit the same privacy level:
- Devices
- Sites
- Floors
- Analytics modules
- APIs
- Data exports
No module can override this locally.
Configuration & visibility
What customers see
- Current privacy level (read-only once locked)
- Enabled / disabled capabilities
- Effective date
- Authority who approved it
What they can change
- Only what is permitted within that level
- Some settings are:
- User-adjustable
- Account-creation-only
- Locked entirely
Audit trail (compliance-grade)
Every privacy-relevant action is logged:
- Privacy level selection
- Changes attempted (allowed or rejected)
- Module enablement (Wi-Fi, BLE, etc.)
- Data access attempts
- Export attempts
- API access
- Retention changes
These logs are:
- Immutable
- Timestamped
- Attributable
- Exportable for audit
This supports:
- Internal audits
- External auditors
- Regulatory inquiries
- Customer self-assurance
What this means for executives
- Privacy is a board-level choice, not a technical accident
- Risk is visible, bounded, and documented
- Enforcement is systemic, not procedural
- Compliance evidence exists before it is requested
This is particularly relevant in people-counting, where perception risk often exceeds actual risk.