Data processing

Current as of 5 Feb 2026

This document provides the specific details of the data processing activities to be performed by Rooya as required by Data Protection Legislation.

1. Subject Matter of Processing

The provision of AI-driven fleet safety and risk management services through the Rooya Vision Telematics System, including the capturing, transmission, and analysis of telematics and video data from equipped vehicles.

2. Duration of Processing

For the duration of the Agreement:

Non-Incident Video: Not stored (processed at edge and discarded).
Incident-Related Video: Retained for 12 months in an active S3 bucket for client inspection/insurance claims.
Post-12 Months: Data is anonymised and moved to long-term storage for AI training and system analytics (at which point it is no longer personal data).

3. Nature and Purpose of Processing

Nature: Automated collection via hardware, cloud-based storage, AI algorithmic analysis for behaviour detection, and reporting via a digital portal.
Purpose: To improve road safety, reduce insurance risk, support incident management, and provide evidence for insurance claims.

Data Type	Specific Elements
Identification & Contact	Driver name (if provided by Customer), vehicle registration mark (VRM), and device ID.
Telematics Data	Real-time GPS location, trip history, speed, acceleration, braking, and cornering forces.
Visual Data (Road)	External video footage capturing the driving environment, third-party vehicles, and pedestrians.
Visual Data (Cabin)	Driver-facing video footage used for the analysis of posture and head position.
Behavioural Insights	AI-generated indicators of seatbelt usage, mobile phone use, distracted driving, and fatigue.

4. Special Category Data (Inferred)

The processing includes the detection of Fatigue and Distraction. Under the UK GDPR:

These are processed as inferred health data (Special Category Data) solely to assess safe vehicle operation.
Facial Recognition: Rooya does not use biometric data for the purpose of uniquely identifying a natural person. AI analysis is limited to behavioural state detection.

Categories of Data Subjects

Monitored Vehicle Operators (MVOs): Employees, independent contractors, or authorized drivers of the Customer.
Third Parties: Pedestrians, other motorists, and members of the public captured incidentally by road-facing cameras.