Robot Camera Privacy Notice — London Gatwick

Information Collected
Pattern Labs operates autonomous baggage handling robots at London Gatwick, run day to day by DHL. The robots have cameras that record video of anyone in their field of view, including faces, bodies, clothing and hi-vis markings. Alongside each frame we record the robot's identity, position, speed, zone and the time. The cameras cannot read name badges, passes or baggage tags. No audio is recorded and no microphones are fitted. We do not use facial recognition and we do not create biometric data. The frames the robot uses to drive and to detect obstacles are not stored.

Why we Collect Information
We collect footage for the following purposes:

1. To let the robot locate itself, detect obstacles and stop safely;

2. To investigate incidents, near-misses and faults;

3. To support remote assistance, where a DHL operator views the cameras live and takes control, which is not recorded;

4. To train and test the software that performs the localisation and obstacle detection;

5. To provide footage to DHL for its own safety reporting;

6. To comply with any applicable laws and regulations.

We rely on legitimate interests for these purposes, namely operating heavy autonomous equipment safely around people. We also rely on legal obligation where we are required to keep or disclose incident footage, for example under RIDDOR or at the lawful request of the Civil Aviation Authority, the Health and Safety Executive or the police. We do not rely on consent. We do not use footage to identify anyone, and we do not use it to monitor anyone's performance or conduct at work.

How we Store, Use, Share, and Disclose Footage
Footage is held by Pattern Labs in the United States and stored on Google Cloud Platform, which acts only on our instructions. Google LLC is certified under the UK Extension to the EU–US Data Privacy Framework. UK data protection law applies to this processing and your rights are unaffected. Footage is encrypted in transit and at rest, and access is limited to named staff and logged.
We share footage with DHL, which becomes a separate controller for its own copy; with Gatwick Airport Limited for incidents on their estate; with insurers, loss adjusters and lawyers handling a claim; and with the Civil Aviation Authority, the Health and Safety Executive or the police on a mandatory report or valid lawful request. We do not sell footage and we do not use it for marketing.

How Long we Keep Footage
Recorded footage is kept for 7 days and then deleted automatically. Where a clip is exported for an incident investigation, we keep it for as long as the investigation, the report or any resulting claim requires, and delete it no later than 12 months after that concludes. Footage selected to train and test our software is kept in a training dataset for up to 12 months. If you want a copy of footage you appear in, please contact us within 7 days, as after that there will be nothing left to provide.

Your Rights
You can ask for access to footage of you, ask us to erase it, ask us to restrict its use, object to us holding it, or ask us to correct inaccurate details recorded alongside it. Portability does not apply, because we rely on neither consent nor a contract with you. There is no charge and we will respond within one month.
Footage is not indexed by identity and we do not run face matching to search it, so please tell us the date, the approximate time, where you were and how we would recognise you. We will ask you to prove your identity before we release any images. Where other people appear in the footage we protect their privacy before release, either by blurring them or by offering you a supervised viewing instead.

How to Make a Request or Complain
Email adventue@patternlabs.ai, or write to Pattern Labs, Inc., 3000 Airport Drive, Erie, CO 80516, United States.

 

Notice Updates
We will update this page before any change to the cameras, to what we do with footage, or to how long we keep it takes effect. Version 1.0, 21 September 2026.