Innovation
NS regularly implements new innovations to make its services cheaper, more efficient and better for travellers, for NS itself, and for third parties. NS pursues innovation in many different ways, some of which involve processing personal data. NS only uses personal data if suitable precautions have been taken to shield the personal data in order to ensure compliance with legislation, minimise risk and mitigate any negative consequences for the personal lives of those involved.
We use various types of personal data for this purpose, ranging from indirectly identifiable data to pseudonymised and anonymised data. This includes OV-chipkaart data, camera footage without identifiable images of people, customer data or online data from users of the NS app or website.
Examples of innovations include crowd or incident based on information from the gates at Utrecht Central station or our bicicyle storage facilities to improve our safety measures in the event of a fire or an emergency. The camera footage used for this analysis are blurred or stored in a low-quality format where possible to ensure that none of the people in the footage can be identified. Another example is using travel data to build a so-called fictional data set, which NS can use to test applications for safety and user friendliness without using real personal data.
We may also analyse travel data, revenue and travel products to make sure that the travel products and timetables we offer meet people's needs and wishes. NS also uses stills to create visual overviews of all of its assets. These stills are anonymised with an algorithm, effectively minimising any processing of personal data and license plates, so that they can be used for a variety of different purposes.
Personal data are only used if strictly necessary for the sake of analysis. Personal data will never be included in the final product or the information product itself, and individuals will never be the subject of such an analysis. The only exception to this is the use of footage that may still contain identifiable personal data (approximately 1% of all footage). This footage is used to train AI-based techniques for train automation based on camera footage (approx. 1% of all footage may contain identifiable information) and/or to investigate whether unauthorised access to bicycle storage facilities can be detected through image analysis. NS is currently testing these technologies and may store the corresponding footage for approximately 5 years. We review whether the footage is needed to validate the technology every year. NS believes that it has a justified interest in processing these data due to the interests of travellers, NS and third parties, the limited impact on the personal lives of those involved, the fact that these data are not processed purposefully and that NS will never link identifiable personal data or other identifiable passenger data to this footage.
The processing of personal data only takes place on the basis of the legitimate interest of NS. However, this depends upon the innovation, the type of personal data and the other features of the innovation.
It is an inherent part of the innovation process that not all ideas ultimately materialise. However, if an innovation does lead to structural data processing, this will be explicitly described in this privacy statement.