What are privacy-first occupancy sensors?
Privacy-first occupancy sensors detect presence and movement without capturing personally identifiable images.
- Thermal sensing: detects heat signatures (people’s body heat) rather than optical images.
- Passive infrared (PIR): detects motion via infrared energy changes.
- Radar and sonar: detect movement and distance using radio or sound waves.
- Device-free, anonymized signal processing: on-device (edge) analytics produce counts or heatmaps rather than raw sensor feeds.
Definition: edge processing — analyzing sensor data locally on the device or gateway so only aggregated, anonymized results leave the sensor network.
Butlr, for example, offers an AI-driven thermal, camera-free sensing platform that focuses on spatial intelligence while preserving privacy (see butlr.com).
Why privacy-first matters in the UK & Germany (2026)
Privacy-first sensors reduce legal, ethical, and workforce risks while enabling efficiencies such as energy savings, space utilization, and safer occupancy monitoring.
Key legal context
- UK: Data Protection Act 2018 and UK GDPR govern personal data processing; the Information Commissioner’s Office (ICO) issues guidance.
- Germany: EU GDPR applies alongside the Federal Data Protection Act (BDSG). State data protection authorities (Landesdatenschutzbeauftragte) and the Federal Commissioner (BfDI) enforce rules. Employee monitoring is especially sensitive; works councils (Betriebsrat) have consultation rights.
- Emerging AI and IoT regulation: In 2026, building owners should monitor evolving EU/UK AI and IoT guidance that may affect algorithmic decision-making and transparency obligations.
Privacy-first sensors help meet compliance by minimizing personal data, enabling data protection by design, and simplifying impact assessments.
Core privacy and compliance steps
1. Conduct a Data Protection Impact Assessment (DPIA)
DPIA: a documented risk assessment required under GDPR when processing may result in high risk to individuals.
Scope: describe sensor locations, data types (counts, heatmaps), retention, access, and security controls.
Outcome: mitigation measures, lawful basis, and a record for supervisory authorities.
2. Determine lawful basis and purposes
Typical lawful basis: legitimate interests (e.g., building safety, energy optimization) with a balancing test, or contractual necessity. Consent: rarely practical for general building occupancy sensing; if processing could identify individuals, consent or stronger safeguards may be needed.
3. Engage stakeholders early
Inform and consult employees, tenants, and — in Germany — works councils where monitoring affects staff. Provide clear notices and privacy information explaining what is collected, why, retention periods, and contact points.
4. Limit and anonymize data
Only collect what’s necessary (data minimization). Prefer aggregated counts and zone-level occupancy over identifiable traces. Use on-device anonymization to prevent raw sensor streams from leaving the premises.
5. Set retention and deletion policies
Keep raw or fine-grained data only as long as needed; consider short retention windows (e.g., hours to days) for high-granularity data. Record aggregated historical metrics longer for analytics, with appropriate safeguards.
6. Secure the system
Implement encryption in transit and at rest, strict access controls, role-based permissions, and logging. Segment sensor networks from corporate IT where feasible.