The privacy of individuals and entities imaged by Keystone Aerial Surveys, Inc. (Keystone) is an important concern for all manned and unmanned airborne, spaceborne or ground sensing. The policies contained below must be adhered to by all Keystone personnel when working with customer data.
“Imaging”\”Imagery” – Any form of collecting data that results in products that can be used to identify a person, vehicle or other personally identifiable items. For Example, LiDAR point clouds are considered to be imagery for the purpose of this document. Other types of imagery include thermal, multi-spectral, High Definition Video, etc.
“Covered Data” – information collected by Keystone that identifies a particular person.
“Data Subjects” - individuals about whom covered data is collected.
Scope of Work
- Keystone’s purpose for collecting imagery is to assist in the creation of maps, elevation models, 3D models, inspection of infrastructure, crop monitoring and related engineering, mapping, construction and planning tasks. This work is both for private and public purposes.
- Keystone’s purpose is NOT to obtain Covered Data. The only exceptions to this rule will be Covered Data collected at the direction of state or federal government agencies with authority to obtain such data, or with the express consent of the Data Subject(s). Keystone understands that it may collect Covered Data in the course of performing the data collection for the purposes stated above. The notification, privacy and security statements below detail the steps Keystone and all its employees and sub contactors must follow when Covered Data is collected.
Notification of Data Collection: UAS
- As per FAA guidelines, Keystone will not fly above private property without consent of the owners and will not fly above persons without their permission.
- As per Keystone’s Flight Operations Manual, Keystone will obtain written permission from both the primary owner\representative of the primary survey property and any surrounding properties that the UAS may fly over. The UAS may only fly over these properties with permission from the owner\representative.
- All persons associated with the survey (who have signed the proper consent form) and the property owner\representatives will be given the option to have a copy of the imagery that contains imagery of Covered Data.
- If Keystone collects Covered Data in the course of performing data acquisition, this information will be excluded from deliverables through the use of editing techniques. Persons and identifiable information such as a vehicle license plate will be blurred. Use of these techniques is intended to ensure that no Covered Data will be part of a deliverable.
- Keystone will not edit information that is visible to a pedestrian or vehicle using the naked eye or with camera equipment. For example, address numbers, signage, etc. will not be removed from delivery products, but faces, license plates, etc. will be blurred.
- Covered Data captured by Keystone will be kept in raw format for recreation of products as needed to meet client needs. As clients often do not discover minor issues with products for some months or have data loss problems, Keystone will retain raw data for one year from the time of capture.
- As noted in the Employee Handbook and the confidentiality document signed by all Keystone employees, information about Keystone and client activities must be protected. In addition, Covered Data or details about what may be contained in Covered Data are in no way to be shared or posted on any social media.
- If Keystone wishes to use Covered Data for marketing or promotional purposes it will obtain written consent from the Data Subjects imaged in the Covered Data. Keystone may use imagery it acquires which is not Covered Data for promotional purposes.
- Keystone will maintain Covered Data on its servers during the creation of delivery products. These servers are not accessible via the web and will only be accessed by the processing team.
- No raw imagery with Covered Data will be loaded to a hosting site for client inspection.
- Covered Data will be moved to archival media shortly after products are delivered. The archival medial will be kept at Keystone’s secure facility at a restricted access airport base.
- As part of Keystone’s larger Information Technology protocol, regular system monitoring for data breach and system health are conducted to ensure the integrity of the systems.
A copy of this policy will be placed on Keystone’s web site and feedback or concerns about the policy, potential violations, omissions or concerns should be addressed in an email to firstname.lastname@example.org or through the website.