Purpose limited to safety and emergency response
Positions are used to send a team to an incident, to guide a responder, to spot an uncovered zone and to document an event afterwards. They are used for nothing else.
Location data
A system that tracks positions has to say what it does with them.
Bermud produces location data about people. Some of it concerns employees during their shift, which makes it a question of employment law as much as of data protection. Here is the position we hold, and which will be written into the contract with each organiser.
01Principles
Four commitments, before any deployment.
No personnel management use
The data is not usable for working time monitoring, for individual assessment, or for disciplinary proceedings. That commitment appears in the organiser’s contract.
Short and bounded retention
Detailed positions are kept for the duration of the event and its report, then deleted. What remains for regulatory obligations is aggregated, apart from records tied to a specific incident.
Information and employee consultation
The people carrying a tag are told what is recorded and who has access to it. Employee representative bodies are consulted before the deployment begins.
02What the system processes
What is recorded, and for how long.
The final detail will depend on the deployment and will be formalised with each organiser. The intended framework is as follows.
| Tag identifier | Linked to a person only for the duration of the event, then unlinked |
|---|---|
| Position | Coarse, at zone level, in normal operation; precise only during an active search or an alert |
| Alerts | Timestamp, position, identity, team dispatched, response time |
| Attendee groups | Temporary association between tags, erased when the tags are returned |
| Access | The organiser’s control room, with consultation logging |
The tag is not under continuous tracking. In normal operation it transmits about once a minute, which gives no more than a presence at zone level. A fine position only exists during an active search or an alert. That design comes from an energy constraint, and it limits in passing how granular the recorded data can be.
03On the attendee side
A tag gets handed back, an app stays behind.
The tag is issued at the gate and returned on the way out. The link between a tag and a person exists for the duration of the festival, then disappears. There is no account to create, no app to install, and nothing left on a phone after the event.
Within a group, each person sees only the members of their own group. The make-up of the group is decided by the people concerned at the moment of pairing, and the organiser does not use it for anything else.
Radio frequency exposure
A tag transmits at a power well below that of a mobile phone, and it transmits far less often. We provide the figures to any organiser who needs them to answer festival-goers or staff representatives.
04Your rights
On a deployment, the data controller is the event organiser, and Bermud acts as a processor within the meaning of the GDPR. Requests for access, rectification or erasure go to the organiser, who passes on to us any that concern us.
For any question about this document or about the processing of data by Bermud, write to erwan.giry.fouquet@gmail.com.
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