CPH continuously monitors the number and flow of passengers through the airport for statistics, operational and emergency reasons.
The counts are made using sensors or registration of connection to CPH FREE WIFI. In this connection MAC addresses are collected, however immediately hashed. Further counts are made by registration of MAC addresses from devices with enabled WiFi or Bluetooth. However, the MAC addresses are immediately anonymized and hashed.
If you do not want this, we recommend that you deactivate Bluetooth and WiFi and do not use CPH Free WiFi on your device.
3.3.1 The personal data processed in the various functions at CPH are the following:
- Sensor information*
- MAC address
CPH has taken the view that waiting time counts and flow analysis using sensors can be linked to individuals. However, the data is processed in pseudonymized form and CPH does not refer the data from passenger and waiting time counts via sensors to specific individuals.
The same view applies to registered MAC addresses from devices with activated WiFi or Bluetooth, despite this information is immediately anonymized and hashed and for registered MAC addresses when connection til CPH FREE WIFI.
3.3.2 Purpose
CPH continuously monitors the number and flow of passengers through the airport for statistics, operational and emergency reasons.
CPH uses a number of technologies including sensors in different locations in the airport to calculate the average waiting times in the security check as well as for other analysis purposes, including for staffing purposes.
Although these sensors themselves do not collect personal data, CPH has taken the view that the conuts in some cases can be linked to individuals via compilation with other information. However, CPH does not refer the information to specific individuals, but only uses the information for the purposes referred to above.
3.3.3 Basis of processing
To the extent that information from passenger and waiting time counts can be linked to a specific individual, the information is processed on the basis of Article 6.1.F of the GDPR (the balancing of interest provision). The legitimate interests pursued by CPH is to measure the waiting time in the security check and to make analyzes regarding the use of the airport terminals, including for staffing purposes, statistics, and operational and emergency reasons.
In the balancing of interest, the fact that CPH does not compile data with other data sources, why the information is not related to specific individuals, is included.
3.3.4 Recipients
In special circumstances, CPH may share relevant data with the Danish authorities, if required.
3.3.5 Erasure
Information from waiting counts via sensors is only identifiable when it is possible to compile it with additional information from e.g. CCTV footage or information from the validation of your boarding pass. When the information from the CCTV footage or the information from the validation of the boarding card is deleted after respectively maximum of 30 days and 3 months, the information from the waiting time counts is anonymized, as they no longer can be related to a person.
Registered MAC addresses in connection to CPH FREE WIFI are deletes in accordance with the specific section concerning this topic above.
Collected MAC addresses in other situations, including passenger counts in baggage reclaim area, are immediately anonymized and hashed, via an algorithm, which changes after no later than 24 hours.