Privacy policy
AbleCenter
®
AC-02 and AC-03
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Data controller is Ablecon AS (Norway) and AbleCenter VisioSales AS.
We do not collect contact information from the user of AbleCenter® AC-02 and AC-03. We only collect data necessary for correct invoicing and customer support.
AbleCenter® AC-02 and AC-03 is developed with
privacy as base principle. We have implemented a
number of security features to protect the collected
data.
Here you can find out more about data we collect,
security measures we implement and which rules
apply when NAV aid centres, private persons,
companies, organisations, schools, or municipalities
purchase AbleCenter® AC-02 and AC-03.
Personal information (GDPR). When AbleCenter® AC-02 and AC-03 is in use, a direct video feed is transmitted from the AbleCenter-device to a dedicated AbleCenter app/ software that the pupils and employees use on their PC, tablet or mobile phone in the same room/ classroom. This means that the network is local inside the building in the same way as any home network. The AbleCenter network is not used to access the Internet or connect to other servers or networks. The AbleCenter network is only used for transmitting the video feed from the AbleCenter-device to the users' PC or tablet at the desk in the same room. The video feed is end-to-end encrypted, to ensure that no-one else than the user of the AbleCenter app/software gains access to what happens in the classroom. At the outset the video feed can not be save, neither by AbleCon As, the user or others. However, if this feature is needed, it can be activated by AbleCon AS.
We gather only name and contact information
about our customers, which for instance can be
NAV aid centre, school, organisation or
municipality. We usually do not know who the
user of AbleCenter® AC-02 and AC-03 is, but only
who the AbleCenter device was purchased by. If
Ablecon AS is given the job of installing and
provide basic training in the use of our system,
our specialists will, as a result of this know who
the user is, but this information is not saved
anywhere at Ablecon AS All future follow/up and
training is delivered based on orders from the
purchaser of the system, for instance NAV aid
centre or school/educational facility. The
AbleCenter software/app collects only data
necessary for customer support and correct
invoicing.
Data that is collected:
The information is only related to the AbleCenter®
AC-02 and AC-03 serial number and purchaser, and
it is therefore not possible to identify who the
software/app user is.
Data can at any time be deleted upon request by
sending an email to [email protected].
Embedded PRIVACY To safeguard the privacy of users and people connected to the system, and ensure the video feed is as secure as possible, we have implemented a number of security measures. Some examples include:
• The system can be switched off and on with the enclosed remote control unit.
• End-to-end encryption of video feed.
• Possible to save up to 9 fixed positions/camera angles and zoom levels.
• Possible to lock the camera to 9 fixed positions (educational objectives).
• Possible with wire connected communication and control via the electrical grid.
• The system can be limited to only one active user at a time.
Password protected login for AbleCenter software.
• Password protected login for wireless network.
• Possibility to record video feed is deactivated as standard (can be activated when needed).
• «Take picture» function active as standard. Can be deactivated by the educator/administrator.
• Choice of server and security
Specialists and technical personnel at AbleCon AS
sign a duty of confidentiality and have access to
the information mentioned above. The
information is never transferred to third parties
except our data processors, unless as a result of
compulsory legal requests. AbleCon will notify
the registered persons by requests for information,
unless specifically stated in the legal procedures
that notification is illegal.
AC-03-device clearly indicates when the system
is on and a user connected.
When the system is switched on a red lamp lights
up on the AbleCenter-device. When a user is
connected to the AbleCenter® AC-03, a green lamp
lights up on the AbleCenter-device so that
everyone around can see that the system is active.
AbleCenter® AC-02 and AC-03 can be switched
off.
If use of AbleCenter® AC-02 and AC-03 is not
required, the device can be switched off by the
enclosed remote control. This limits the danger of
compromising the security of the system.
End-to-end encrypted video feed.
The video feed that is transmitted between the
AbleCenter device and the AbleCenter software/app
on the PC/tablet, is end-to-end encrypted. This way
we ensure that outsiders can not gain access to the
video feed.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Possibility to save up to 9 fixed positions.
AbleCenter® AC-02 and AC-03 can save up to 9
fixed positions/camera angles and zoom level using
the numbered buttons 1-9. By selecting the number
of desired setting, the camera moves automatically
to the saved position and saved zoom level. This
happens so fast that it is practically impossible to
interpret the image from one position to another. By
using fixed positions it is of course not possible to
receive other information than that which is located
within the saved position
Possibility to lock the system to 9 fixed positions.
AbleCenter® AC-02 and AC-03 can be locked to
fixed positions/camera angles that are saved and
approved by the educator/administrator
beforehand. This prevents user at home or outsiders
from receiving images outside the pre-set fixed
areas
Possibility for wire-connected communication
and control through the electrical grid.
If you do not wish to use the local wireless network
to control the system and direct the video feed, this
can be managed through a simple component that is
plugged into a wall socket which communicates
with a small unit plugged into the network port of
the PC. This makes it impossible for intruders to
gain access to this line, and the need for more
internal networks is eliminated.
One user.
The device can only be connected with one user at a
time through a fixed IP-address, but it is possible to
open up for more if required. Be aware, that this
reduces the security level of the system by some
degree.
Password protected login for AbleCenter software.
In order to use the software/app for AbleCenter®
AC-02 and AC-03 the software must be activated
with a code from Ablecon AS.
Password protected login for wireless network.
In order to manage the system through the wireless
network, one must log into an end-to-end encrypted
network med SSID and password.
Nothing is saved.
AbleCenter® AC-02 and AC-03 is used in real time.
The possibility to save the video feed is deactivated as
standard, but can be activated by contacting
AbleCon AS.
AbleCenter® AC-02 and AC-03 can be compared to a
pair of binoculars that offer the chance for a person
with vision impairment to see required positions in
the classroom to take part in the education process
on equal terms with other pupils and, to a certain
extent, participate in the social life in class.
The «Take picture » feature is active as standard but
can be deactivated by contacting AbleCon AS
Your rights.
You have the right to ask for insight, correction and
deletion of your personal information. Du may also
complain to the Norwegian Data Protection
Authorithy.
Personal data (GDPR).
Ablecon AS has conducted some research in
connection with our camera systems for vision
impaired pupils that have become very popular in
Norwegian school. We have studied the regulations
from NDPA connected to duty of information by the
use of a camera in the classroom.
As we have also developed a system that can transmit
video feed outside the building and home to home-based pupils (AbleCenter® AC-03 with home
control module) where we use systems that transmit
images and sound from the classroom to a
homebased pupil, we felt it necessary to to properly
investigate responsibility and privacy issues. This
was completed as part of a pilot-study preceding the
development of AbleCenter® AC-03 with home
control module.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
We conducted a thorough mapping, mainly
through web-based tools. We found a lot of
information but in this connection we would refer
to a statement from the Ministry of Knowledge
dated 19.05.2017
The statement is regarding the use of robot with
the possibility of two-way transmission of sound
and one-way transmission of video from the
classroom to a pupil based somewhere else. This
robot is designated AV1 and in the statement is
referred to as either «robot» or «AV1».
We must here underline that this statement is
regarding the use of robot with the possibility of
two-way transmission of sound and one-way
transmission of video from the classroom to a
pupil based somewhere else.
This means that the data feed is sent outside the
building and would therefore probably demand
more in relation to privacy and security than
AbleCenter® AC-02 and AC-03 which only
communicate between two devices locally in the
same room. Regarding AbleCenter® AC-02 and
AC-03 we are therefore uncertain whether the
Personal Information Act applies to the systems.
Camera based tools for pupils with vision
impairment, both distance camera and closeup
camera have been a natural part of classrooms,
where there are pupils with vision impairments,
for a number of years already. As far as we are
aware, these systems have not resulted that the
Personal Information Act has been applied
during all these years.
We would still always refer to this statement,
though, as it looks like areas covered by the
Personal Information Act must be adhered to by
the school or workplace. In situations where this equipment is used for the
school/education facility to fulfill its teaching
obligations, it is the education facility that has
processing responsibility for the processing of
personal data.
The way we interpret the statement
from the Norwegian Data Protection Authority, it
seems to cover the use of a system with the
possibility of two-way transmission of sound and
one-way transmission of images from the classroom
to a student who is in another place, where the
student can control the movement of the system and
thus image sections and communicate with audio
via network access. Where the purpose is for the
student to be able to take part in the school's and
school owner's educational process, the processing
of personal data is not carried out for private
purposes, but for training purposes. The Personal
Information Act then applies and the school owner
is responsible for processing, and must fulfill the
obligations according to privacy regulations. The
fact that the Personal Information Act applies,
means that the school owner must ensure that the
criteria in the Act are fulfilled.
Amongst other things, the Act stipulates criteria for
basis for data processing, for instance acceptance
(Personal Information Act §8 and §9) and
information to those affected by data processing and
storage (Personal Information Act §19) etc. As data
processing responsible the school owner has, in
addition, a number of obligations connected to
internal control and information security (Personal
Information Act §13 and §14).
From our point of view, this appears initially to be
about providing good and accurate information and
also collect user consent by the use of such tools. We
have therefore developed written materials that
make the information process easier for the school
and work place. This information can be
downloaded from our web page at
www.ablecenter.no/personvern.
If use of the system involves the use of the school
owner's network, the school owner must, among
other things, decide what risk it entails to allow the
use of ICT equipment on the school's network over
which the school owner himself has no control. This
assessment will be the same as for all other
equipment (PCs, tablets and smartphones etc.) that
staff and pupils use on the school's network, and
which the school owner does not control.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
In higher education it is normal that the students
already at matriculation, have signed adequate
consent forms regarding this. Adequate
information to affected parties is critical.
By different uses in professional work life, this
should be investigated closer by the employer.
Frequently Asked Questions (FAQ).
Below we have gathered answers to the most
common questions.
When an educational facility/municipality has
purchased and started using AbleCenter® AC-02
and AC-03, they must ensure that the criteria in
the Personal Information Act are met.
What does the NDPA say.
The Norwegian Data Protection Authority stated
the following about cases where a robot with the
possibility of two-way transmission of sound and
one-way transmission of images from the classroom
to a student who is in another place, where the
student can control the movement of the system
and thus image sections and communicate with
audio via network access, is used. Where the
purpose is for the student to be able to take part in
the school's educational process, the processing of
personal data is not carried out for private
purposes, but for training purposes. The Personal
Information Act then applies and the school owner
is responsible for the processing, and must fulfill
the obligations according to the privacy regulations.
The NDPA also stated the following about cases
where AV1 (This robot has the designation AV1
and is referred to in the statement as either
"robot" or "AV1") is purchased by the school/
municipality in 2017 :
"The school owner must ensure that the
requirements in the Personal Information Act are
met. Among other things, the Act requires a basis
for processing, e.g. consent (Personal Data Act §8
and §9) and information to those affected, etc.
(Personal Information Act §19). As data
controller, the school owner also has a number of
duties related to internal control and information
security (Personal Data Act §13 and §14).
If use of the system means use of the school owners
network, the school owner must consider the risk
involved in allowing the use of ICT equipment that
the school owner does not control.”
Information to affected parties.
It is good policy to inform affected parties, but it is
up to you how this is done. We have developed two
draft information sheets where one is sent to
teachers and pupils and the other can be sent to
parents and next-of-kin at home.
Data processing basis.
This is a short summary of a longer evaluation of
the data processing basis. Contact us by email to
[email protected] if you want to receive complete
evaluation document.
Consent.
Consent from all pupils, teachers and others that
may come into contact with the AbleCenter device
during use, is one possible way for schools to
ensure a valid data processing basis. Consent is
though, but one of several alternative data
processing bases defined in the Personal
Information Act. Since AbleCenter® AC-02 and
AC-03 is also used by children, consent might be
unsuitable as data processing basis. Consent from
children is not considered valid, and it would
therefore be necessary that parents or legal
guardians give consent on behalf of the child.
Justified interest.
Schools may also process personal data if there is a
defined «justified interest».
It is AbleCon's evaluation that AbleCenter® AC-02
and AC-03 is designed in a privacy friendly way
which at the same time fulfills an important
purpose, namely to ensure that pupils with vision
impairments can take part in education on equal
terms with their class mates.
The use of AbleCenter® AC-02 and AC-03 is a good
tool for meeting the criteria for adapted education,
as set out in the Education Act (Education Act
§1-3)
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Based on this, it is the opinion of AbleCon AS that
a clear «justified interest» exists for schools to start
using AbleCenter® AC-02 and AC-03. It is still,
though, the responsibility of the individual school
to justify their own evaluation of whether «just
interest»is present.
In the evaluation of whether a just interest is
present, one must first consider whether the use of
AbleCenter® AC-02 and AC-03 is
«necessary», i.e. whether the purpose for using
AbleCenter® AC-02 and AC-03 can be achieved in a
less intrusive manner. Having considered whether
the measures are «necessary» one must conduct an
evaluation and balancing of interests between the
school's desire to use AbleCenter® AC-02 and
AC-03 and any negative privacy consequences for
the affected pupils and teachers. Special
consideration must be made for cases where the
affected are under age.
Is a data processing agreement necessary?
During the use of AbleCenter® AC-02 and AC-03,
AbleCon AS does not store any personal data on
behalf of their users/customers. AbleCon only
processes the following data to ensure good
customer support and correct invoicing:
• Name of purchaser, order number and reference
number.
AbleCon AS is data processing controller for the
processing of this data and it is not necessary for
our customers or dealers to enter into a specific
data processing agreement with us.
Contact us
AbleCon AS
Trudvangveien 67
3117 Tønsberg, NORWAY
reg. nr. 916151764 | Tel: +(47) 40 08 20 11
[email protected] | www.ablecon.no
reg. nr. 916151764 | Tel: +(47) 40 08 20 11
[email protected] | www.ablecon.noAbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Privacy policy
AbleCenter® AC-02 and AC-03
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Data controller is Ablecon AS (Norway) and AbleCenter VisioSales AS.
We do not collect contact information from the user of AbleCenter® AC-02 and AC-03. We only collect data necessary for correct invoicing and customer support.
AbleCenter® AC-02 and AC-03 is developed with
privacy as base principle. We have implemented a
number of security features to protect the collected
data.
Here you can find out more about data we collect,
security measures we implement and which rules
apply when NAV aid centres, private persons,
companies, organisations, schools, or municipalities
purchase AbleCenter® AC-02 and AC-03.
Personal information (GDPR). When AbleCenter® AC-02 and AC-03 is in use, a direct video feed is transmitted from the AbleCenter-device to a dedicated AbleCenter app/ software that the pupils and employees use on their PC, tablet or mobile phone in the same room/ classroom. This means that the network is local inside the building in the same way as any home network. The AbleCenter network is not used to access the Internet or connect to other servers or networks. The AbleCenter network is only used for transmitting the video feed from the AbleCenter-device to the users' PC or tablet at the desk in the same room. The video feed is end-to-end encrypted, to ensure that no-one else than the user of the AbleCenter app/software gains access to what happens in the classroom. At the outset the video feed can not be save, neither by AbleCon As, the user or others. However, if this feature is needed, it can be activated by AbleCon AS.
We gather only name and contact information
about our customers, which for instance can be
NAV aid centre, school, organisation or
municipality. We usually do not know who the
user of AbleCenter® AC-02 and AC-03 is, but only
who the AbleCenter device was purchased by. If
Ablecon AS is given the job of installing and
provide basic training in the use of our system,
our specialists will, as a result of this know who
the user is, but this information is not saved
anywhere at Ablecon AS All future follow/up and
training is delivered based on orders from the
purchaser of the system, for instance NAV aid
centre or school/educational facility. The
AbleCenter software/app collects only data
necessary for customer support and correct
invoicing.
Data that is collected:
The information is only related to the AbleCenter®
AC-02 and AC-03 serial number and purchaser, and
it is therefore not possible to identify who the
software/app user is.
Data can at any time be deleted upon request by
sending an email to [email protected].
Embedded PRIVACY To safeguard the privacy of users and people connected to the system, and ensure the video feed is as secure as possible, we have implemented a number of security measures. Some examples include:
• The system can be switched off and on with the enclosed remote control unit.
• End-to-end encryption of video feed.
• Possible to save up to 9 fixed positions/camera angles and zoom levels.
• Possible to lock the camera to 9 fixed positions (educational objectives).
• Possible with wire connected communication and control via the electrical grid.
• The system can be limited to only one active user at a time.
Password protected login for AbleCenter software.
• Password protected login for wireless network.
• Possibility to record video feed is deactivated as standard (can be activated when needed).
• «Take picture» function active as standard. Can be deactivated by the educator/administrator.
• Choice of server and security
Specialists and technical personnel at AbleCon AS
sign a duty of confidentiality and have access to
the information mentioned above. The
information is never transferred to third parties
except our data processors, unless as a result of
compulsory legal requests. AbleCon will notify
the registered persons by requests for information,
unless specifically stated in the legal procedures
that notification is illegal.
AC-03-device clearly indicates when the system
is on and a user connected.
When the system is switched on a red lamp lights
up on the AbleCenter-device. When a user is
connected to the AbleCenter® AC-03, a green lamp
lights up on the AbleCenter-device so that
everyone around can see that the system is active.
AbleCenter® AC-02 and AC-03 can be switched
off.
If use of AbleCenter® AC-02 and AC-03 is not
required, the device can be switched off by the
enclosed remote control. This limits the danger of
compromising the security of the system.
End-to-end encrypted video feed.
The video feed that is transmitted between the
AbleCenter device and the AbleCenter software/app
on the PC/tablet, is end-to-end encrypted. This way
we ensure that outsiders can not gain access to the
video feed.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Possibility to save up to 9 fixed positions.
AbleCenter® AC-02 and AC-03 can save up to 9
fixed positions/camera angles and zoom level using
the numbered buttons 1-9. By selecting the number
of desired setting, the camera moves automatically
to the saved position and saved zoom level. This
happens so fast that it is practically impossible to
interpret the image from one position to another. By
using fixed positions it is of course not possible to
receive other information than that which is located
within the saved position
Possibility to lock the system to 9 fixed positions.
AbleCenter® AC-02 and AC-03 can be locked to
fixed positions/camera angles that are saved and
approved by the educator/administrator
beforehand. This prevents user at home or outsiders
from receiving images outside the pre-set fixed
areas
Possibility for wire-connected communication
and control through the electrical grid.
If you do not wish to use the local wireless network
to control the system and direct the video feed, this
can be managed through a simple component that is
plugged into a wall socket which communicates
with a small unit plugged into the network port of
the PC. This makes it impossible for intruders to
gain access to this line, and the need for more
internal networks is eliminated.
One user.
The device can only be connected with one user at a
time through a fixed IP-address, but it is possible to
open up for more if required. Be aware, that this
reduces the security level of the system by some
degree.
Password protected login for AbleCenter software.
In order to use the software/app for AbleCenter®
AC-02 and AC-03 the software must be activated
with a code from Ablecon AS.
Password protected login for wireless network.
In order to manage the system through the wireless
network, one must log into an end-to-end encrypted
network med SSID and password.
Nothing is saved.
AbleCenter® AC-02 and AC-03 is used in real time.
The possibility to save the video feed is deactivated as
standard, but can be activated by contacting
AbleCon AS.
AbleCenter® AC-02 and AC-03 can be compared to a
pair of binoculars that offer the chance for a person
with vision impairment to see required positions in
the classroom to take part in the education process
on equal terms with other pupils and, to a certain
extent, participate in the social life in class.
The «Take picture » feature is active as standard but
can be deactivated by contacting AbleCon AS
Your rights.
You have the right to ask for insight, correction and
deletion of your personal information. Du may also
complain to the Norwegian Data Protection
Authorithy.
Personal data (GDPR).
Ablecon AS has conducted some research in
connection with our camera systems for vision
impaired pupils that have become very popular in
Norwegian school. We have studied the regulations
from NDPA connected to duty of information by the
use of a camera in the classroom.
As we have also developed a system that can transmit
video feed outside the building and home to home-based pupils (AbleCenter® AC-03 with home
control module) where we use systems that transmit
images and sound from the classroom to a
homebased pupil, we felt it necessary to to properly
investigate responsibility and privacy issues. This
was completed as part of a pilot-study preceding the
development of AbleCenter® AC-03 with home
control module.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
We conducted a thorough mapping, mainly
through web-based tools. We found a lot of
information but in this connection we would refer
to a statement from the Ministry of Knowledge
dated 19.05.2017
The statement is regarding the use of robot with
the possibility of two-way transmission of sound
and one-way transmission of video from the
classroom to a pupil based somewhere else. This
robot is designated AV1 and in the statement is
referred to as either «robot» or «AV1».
We must here underline that this statement is
regarding the use of robot with the possibility of
two-way transmission of sound and one-way
transmission of video from the classroom to a
pupil based somewhere else.
This means that the data feed is sent outside the
building and would therefore probably demand
more in relation to privacy and security than
AbleCenter® AC-02 and AC-03 which only
communicate between two devices locally in the
same room. Regarding AbleCenter® AC-02 and
AC-03 we are therefore uncertain whether the
Personal Information Act applies to the systems.
Camera based tools for pupils with vision
impairment, both distance camera and closeup
camera have been a natural part of classrooms,
where there are pupils with vision impairments,
for a number of years already. As far as we are
aware, these systems have not resulted that the
Personal Information Act has been applied
during all these years.
We would still always refer to this statement,
though, as it looks like areas covered by the
Personal Information Act must be adhered to by
the school or workplace.In situations where this equipment is used for the
school/education facility to fulfill its teaching
obligations, it is the education facility that has
processing responsibility for the processing of
personal data.
The way we interpret the statement
from the Norwegian Data Protection Authority, it
seems to cover the use of a system with the
possibility of two-way transmission of sound and
one-way transmission of images from the classroom
to a student who is in another place, where the
student can control the movement of the system and
thus image sections and communicate with audio
via network access. Where the purpose is for the
student to be able to take part in the school's and
school owner's educational process, the processing
of personal data is not carried out for private
purposes, but for training purposes. The Personal
Information Act then applies and the school owner
is responsible for processing, and must fulfill the
obligations according to privacy regulations. The
fact that the Personal Information Act applies,
means that the school owner must ensure that the
criteria in the Act are fulfilled.
Amongst other things, the Act stipulates criteria for
basis for data processing, for instance acceptance
(Personal Information Act §8 and §9) and
information to those affected by data processing and
storage (Personal Information Act §19) etc. As data
processing responsible the school owner has, in
addition, a number of obligations connected to
internal control and information security (Personal
Information Act §13 and §14).
From our point of view, this appears initially to be
about providing good and accurate information and
also collect user consent by the use of such tools. We
have therefore developed written materials that
make the information process easier for the school
and work place. This information can be
downloaded from our web page at
www.ablecenter.no/personvern.
If use of the system involves the use of the school
owner's network, the school owner must, among
other things, decide what risk it entails to allow the
use of ICT equipment on the school's network over
which the school owner himself has no control. This
assessment will be the same as for all other
equipment (PCs, tablets and smartphones etc.) that
staff and pupils use on the school's network, and
which the school owner does not control.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
In higher education it is normal that the students
already at matriculation, have signed adequate
consent forms regarding this. Adequate
information to affected parties is critical.
By different uses in professional work life, this
should be investigated closer by the employer.
Frequently Asked Questions (FAQ).
Below we have gathered answers to the most
common questions.
When an educational facility/municipality has
purchased and started using AbleCenter® AC-02
and AC-03, they must ensure that the criteria in
the Personal Information Act are met.
What does the NDPA say.
The Norwegian Data Protection Authority stated
the following about cases where a robot with the
possibility of two-way transmission of sound and
one-way transmission of images from the classroom
to a student who is in another place, where the
student can control the movement of the system
and thus image sections and communicate with
audio via network access, is used. Where the
purpose is for the student to be able to take part in
the school's educational process, the processing of
personal data is not carried out for private
purposes, but for training purposes. The Personal
Information Act then applies and the school owner
is responsible for the processing, and must fulfill
the obligations according to the privacy regulations.
The NDPA also stated the following about cases
where AV1 (This robot has the designation AV1
and is referred to in the statement as either
"robot" or "AV1") is purchased by the school/
municipality in 2017 :
"The school owner must ensure that the
requirements in the Personal Information Act are
met. Among other things, the Act requires a basis
for processing, e.g. consent (Personal Data Act §8
and §9) and information to those affected, etc.
(Personal Information Act §19). As data
controller, the school owner also has a number of
duties related to internal control and information
security (Personal Data Act §13 and §14).
If use of the system means use of the school owners
network, the school owner must consider the risk
involved in allowing the use of ICT equipment that
the school owner does not control.”
Information to affected parties.
It is good policy to inform affected parties, but it is
up to you how this is done. We have developed two
draft information sheets where one is sent to
teachers and pupils and the other can be sent to
parents and next-of-kin at home.
Data processing basis.
This is a short summary of a longer evaluation of
the data processing basis. Contact us by email to
[email protected] if you want to receive complete
evaluation document.
Consent.
Consent from all pupils, teachers and others that
may come into contact with the AbleCenter device
during use, is one possible way for schools to
ensure a valid data processing basis. Consent is
though, but one of several alternative data
processing bases defined in the Personal
Information Act. Since AbleCenter® AC-02 and
AC-03 is also used by children, consent might be
unsuitable as data processing basis. Consent from
children is not considered valid, and it would
therefore be necessary that parents or legal
guardians give consent on behalf of the child.
Justified interest.
Schools may also process personal data if there is a
defined «justified interest».
It is AbleCon's evaluation that AbleCenter® AC-02
and AC-03 is designed in a privacy friendly way
which at the same time fulfills an important
purpose, namely to ensure that pupils with vision
impairments can take part in education on equal
terms with their class mates.
The use of AbleCenter® AC-02 and AC-03 is a good
tool for meeting the criteria for adapted education,
as set out in the Education Act (Education Act
§1-3)
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Based on this, it is the opinion of AbleCon AS that
a clear «justified interest» exists for schools to start
using AbleCenter® AC-02 and AC-03. It is still,
though, the responsibility of the individual school
to justify their own evaluation of whether «just
interest»is present.
In the evaluation of whether a just interest is
present, one must first consider whether the use of
AbleCenter® AC-02 and AC-03 is
«necessary», i.e. whether the purpose for using
AbleCenter® AC-02 and AC-03 can be achieved in a
less intrusive manner. Having considered whether
the measures are «necessary» one must conduct an
evaluation and balancing of interests between the
school's desire to use AbleCenter® AC-02 and
AC-03 and any negative privacy consequences for
the affected pupils and teachers. Special
consideration must be made for cases where the
affected are under age.
Is a data processing agreement necessary?
During the use of AbleCenter® AC-02 and AC-03,
AbleCon AS does not store any personal data on
behalf of their users/customers. AbleCon only
processes the following data to ensure good
customer support and correct invoicing:
• Name of purchaser, order number and reference
number.
AbleCon AS is data processing controller for the
processing of this data and it is not necessary for
our customers or dealers to enter into a specific
data processing agreement with us.
Contact us
AbleCon AS
Trudvangveien 67
3117 Tønsberg, NORWAY
reg. nr. 916151764 | Tel: +(47) 40 08 20 11
[email protected] | www.ablecon.no
reg. nr. 916151764 | Tel: +(47) 40 08 20 11
[email protected] | www.ablecon.noAbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Privacy policy
AbleCenter® AC-02 and AC-03
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
We do not collect contact information from the user of AbleCenter® AC-02 and AC-03. We only collect data necessary for correct invoicing and customer support.
Data controller is Ablecon AS (Norway) and AbleCenter VisioSales AS.
AbleCenter® AC-02 and AC-03 is developed with
privacy as base principle. We have implemented a
number of security features to protect the collected
data.
Here you can find out more about data we collect,
security measures we implement and which rules
apply when NAV aid centres, private persons,
companies, organisations, schools, or municipalities
purchase AbleCenter® AC-02 and AC-03.
Personal information (GDPR). When AbleCenter® AC-02 and AC-03 is in use, a direct video feed is transmitted from the AbleCenter-device to a dedicated AbleCenter app/ software that the pupils and employees use on their PC, tablet or mobile phone in the same room/ classroom. This means that the network is local inside the building in the same way as any home network. The AbleCenter network is not used to access the Internet or connect to other servers or networks. The AbleCenter network is only used for transmitting the video feed from the AbleCenter-device to the users' PC or tablet at the desk in the same room. The video feed is end-to-end encrypted, to ensure that no-one else than the user of the AbleCenter app/software gains access to what happens in the classroom. At the outset the video feed can not be save, neither by AbleCon As, the user or others. However, if this feature is needed, it can be activated by AbleCon AS.
We gather only name and contact information
about our customers, which for instance can be
NAV aid centre, school, organisation or
municipality. We usually do not know who the
user of AbleCenter® AC-02 and AC-03 is, but only
who the AbleCenter device was purchased by. If
Ablecon AS is given the job of installing and provide basic training in the use of our system,
our specialists will, as a result of this know who
the user is, but this information is not saved
anywhere at Ablecon AS All future follow/up and
training is delivered based on orders from the
purchaser of the system, for instance NAV aid
centre or school/educational facility. The
AbleCenter software/app collects only data
necessary for customer support and correct
invoicing.
Data that is collected:
The information is only related to the AbleCenter®
AC-02 and AC-03 serial number and purchaser, and
it is therefore not possible to identify who the
software/app user is.
Data can at any time be deleted upon request by
sending an email to [email protected].
Embedded PRIVACY To safeguard the privacy of users and people connected to the system, and ensure the video feed is as secure as possible, we have implemented a number of security measures. Some examples include:
• The system can be switched off and on with the enclosed remote control unit.
• End-to-end encryption of video feed.
• Possible to save up to 9 fixed positions/camera angles and zoom levels.
• Possible to lock the camera to 9 fixed positions (educational objectives).
• Possible with wire connected communication and control via the electrical grid.
• The system can be limited to only one active user at a time.
Password protected login for AbleCenter software.
• Password protected login for wireless network.
• Possibility to record video feed is deactivated as standard (can be activated when needed).
• «Take picture» function active as standard. Can be deactivated by the educator/administrator.
• Choice of server and security
Specialists and technical personnel at AbleCon AS
sign a duty of confidentiality and have access to
the information mentioned above. The
information is never transferred to third parties
except our data processors, unless as a result of
compulsory legal requests. AbleCon will notify
the registered persons by requests for information,
unless specifically stated in the legal procedures
that notification is illegal.
AC-03-device clearly indicates when the system
is on and a user connected.
When the system is switched on a red lamp lights
up on the AbleCenter-device. When a user is
connected to the AbleCenter® AC-03, a green lamp
lights up on the AbleCenter-device so that
everyone around can see that the system is active.
AbleCenter® AC-02 and AC-03 can be switched
off.
If use of AbleCenter® AC-02 and AC-03 is not
required, the device can be switched off by the
enclosed remote control. This limits the danger of
compromising the security of the system.
End-to-end encrypted video feed.
The video feed that is transmitted between the
AbleCenter device and the AbleCenter software/app
on the PC/tablet, is end-to-end encrypted. This way
we ensure that outsiders can not gain access to the
video feed.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Possibility to save up to 9 fixed positions.
AbleCenter® AC-02 and AC-03 can save up to 9
fixed positions/camera angles and zoom level using
the numbered buttons 1-9. By selecting the number
of desired setting, the camera moves automatically
to the saved position and saved zoom level. This
happens so fast that it is practically impossible to
interpret the image from one position to another. By
using fixed positions it is of course not possible to
receive other information than that which is located
within the saved position
Possibility to lock the system to 9 fixed positions.
AbleCenter® AC-02 and AC-03 can be locked to
fixed positions/camera angles that are saved and
approved by the educator/administrator
beforehand. This prevents user at home or outsiders
from receiving images outside the pre-set fixed
areas
Possibility for wire-connected communication
and control through the electrical grid.
If you do not wish to use the local wireless network
to control the system and direct the video feed, this
can be managed through a simple component that is
plugged into a wall socket which communicates
with a small unit plugged into the network port of
the PC. This makes it impossible for intruders to
gain access to this line, and the need for more
internal networks is eliminated.
One user.
The device can only be connected with one user at a
time through a fixed IP-address, but it is possible to
open up for more if required. Be aware, that this
reduces the security level of the system by some
degree.
Password protected login for AbleCenter software.
In order to use the software/app for AbleCenter®
AC-02 and AC-03 the software must be activated
with a code from Ablecon AS.
Password protected login for wireless network.
In order to manage the system through the wireless
network, one must log into an end-to-end encrypted
network med SSID and password.
Nothing is saved.
AbleCenter® AC-02 and AC-03 is used in real time.
The possibility to save the video feed is deactivated as
standard, but can be activated by contacting
AbleCon AS.
AbleCenter® AC-02 and AC-03 can be compared to a
pair of binoculars that offer the chance for a person
with vision impairment to see required positions in
the classroom to take part in the education process
on equal terms with other pupils and, to a certain
extent, participate in the social life in class.
The «Take picture » feature is active as standard but
can be deactivated by contacting AbleCon AS
Your rights.
You have the right to ask for insight, correction and
deletion of your personal information. Du may also
complain to the Norwegian Data Protection
Authorithy.
Personal data (GDPR).
Ablecon AS has conducted some research in
connection with our camera systems for vision
impaired pupils that have become very popular in
Norwegian school. We have studied the regulations
from NDPA connected to duty of information by the
use of a camera in the classroom.
As we have also developed a system that can transmit
video feed outside the building and home to home-based pupils (AbleCenter® AC-03 with home
control module) where we use systems that transmit
images and sound from the classroom to a
homebased pupil, we felt it necessary to to properly
investigate responsibility and privacy issues. This
was completed as part of a pilot-study preceding the
development of AbleCenter® AC-03 with home
control module.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
We conducted a thorough mapping, mainly
through web-based tools. We found a lot of
information but in this connection we would refer
to a statement from the Ministry of Knowledge
dated 19.05.2017
The statement is regarding the use of robot with
the possibility of two-way transmission of sound
and one-way transmission of video from the
classroom to a pupil based somewhere else. This
robot is designated AV1 and in the statement is
referred to as either «robot» or «AV1».
We must here underline that this statement is
regarding the use of robot with the possibility of
two-way transmission of sound and one-way
transmission of video from the classroom to a
pupil based somewhere else.
This means that the data feed is sent outside the
building and would therefore probably demand
more in relation to privacy and security than
AbleCenter® AC-02 and AC-03 which only
communicate between two devices locally in the
same room. Regarding AbleCenter® AC-02 and
AC-03 we are therefore uncertain whether the
Personal Information Act applies to the systems.
Camera based tools for pupils with vision
impairment, both distance camera and closeup
camera have been a natural part of classrooms,
where there are pupils with vision impairments,
for a number of years already. As far as we are
aware, these systems have not resulted that the
Personal Information Act has been applied
during all these years.
We would still always refer to this statement,
though, as it looks like areas covered by the
Personal Information Act must be adhered to by
the school or workplace.In situations where this equipment is used for the
school/education facility to fulfill its teaching
obligations, it is the education facility that has
processing responsibility for the processing of
personal data.
The way we interpret the statement
from the Norwegian Data Protection Authority, it
seems to cover the use of a system with the
possibility of two-way transmission of sound and
one-way transmission of images from the classroom
to a student who is in another place, where the
student can control the movement of the system and
thus image sections and communicate with audio
via network access. Where the purpose is for the
student to be able to take part in the school's and
school owner's educational process, the processing
of personal data is not carried out for private
purposes, but for training purposes. The Personal
Information Act then applies and the school owner
is responsible for processing, and must fulfill the
obligations according to privacy regulations. The
fact that the Personal Information Act applies,
means that the school owner must ensure that the
criteria in the Act are fulfilled.
Amongst other things, the Act stipulates criteria for
basis for data processing, for instance acceptance
(Personal Information Act §8 and §9) and
information to those affected by data processing and
storage (Personal Information Act §19) etc. As data
processing responsible the school owner has, in
addition, a number of obligations connected to
internal control and information security (Personal
Information Act §13 and §14).
From our point of view, this appears initially to be
about providing good and accurate information and
also collect user consent by the use of such tools. We
have therefore developed written materials that
make the information process easier for the school
and work place. This information can be
downloaded from our web page at
www.ablecenter.no/personvern.
If use of the system involves the use of the school
owner's network, the school owner must, among
other things, decide what risk it entails to allow the
use of ICT equipment on the school's network over
which the school owner himself has no control. This
assessment will be the same as for all other
equipment (PCs, tablets and smartphones etc.) that
staff and pupils use on the school's network, and
which the school owner does not control.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
In higher education it is normal that the students
already at matriculation, have signed adequate
consent forms regarding this. Adequate
information to affected parties is critical.
By different uses in professional work life, this
should be investigated closer by the employer.
Frequently Asked Questions (FAQ).
Below we have gathered answers to the most
common questions.
When an educational facility/municipality has
purchased and started using AbleCenter® AC-02
and AC-03, they must ensure that the criteria in
the Personal Information Act are met.
What does the NDPA say.
The Norwegian Data Protection Authority stated
the following about cases where a robot with the
possibility of two-way transmission of sound and
one-way transmission of images from the classroom
to a student who is in another place, where the
student can control the movement of the system
and thus image sections and communicate with
audio via network access, is used. Where the
purpose is for the student to be able to take part in
the school's educational process, the processing of
personal data is not carried out for private
purposes, but for training purposes. The Personal
Information Act then applies and the school owner
is responsible for the processing, and must fulfill
the obligations according to the privacy regulations.
The NDPA also stated the following about cases
where AV1 (This robot has the designation AV1
and is referred to in the statement as either
"robot" or "AV1") is purchased by the school/
municipality in 2017 :
"The school owner must ensure that the
requirements in the Personal Information Act are
met. Among other things, the Act requires a basis
for processing, e.g. consent (Personal Data Act §8
and §9) and information to those affected, etc.
(Personal Information Act §19). As data
controller, the school owner also has a number of
duties related to internal control and information
security (Personal Data Act §13 and §14).
If use of the system means use of the school owners
network, the school owner must consider the risk
involved in allowing the use of ICT equipment that
the school owner does not control.”
Information to affected parties.
It is good policy to inform affected parties, but it is
up to you how this is done. We have developed two
draft information sheets where one is sent to
teachers and pupils and the other can be sent to
parents and next-of-kin at home.
Data processing basis.
This is a short summary of a longer evaluation of
the data processing basis. Contact us by email to
[email protected] if you want to receive complete
evaluation document.
Consent.
Consent from all pupils, teachers and others that
may come into contact with the AbleCenter device
during use, is one possible way for schools to
ensure a valid data processing basis. Consent is
though, but one of several alternative data
processing bases defined in the Personal
Information Act. Since AbleCenter® AC-02 and
AC-03 is also used by children, consent might be
unsuitable as data processing basis. Consent from
children is not considered valid, and it would
therefore be necessary that parents or legal
guardians give consent on behalf of the child.
Justified interest.
Schools may also process personal data if there is a
defined «justified interest».
It is AbleCon's evaluation that AbleCenter® AC-02
and AC-03 is designed in a privacy friendly way
which at the same time fulfills an important
purpose, namely to ensure that pupils with vision
impairments can take part in education on equal
terms with their class mates.
The use of AbleCenter® AC-02 and AC-03 is a good
tool for meeting the criteria for adapted education,
as set out in the Education Act (Education Act
§1-3)
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Based on this, it is the opinion of AbleCon AS that
a clear «justified interest» exists for schools to start
using AbleCenter® AC-02 and AC-03. It is still,
though, the responsibility of the individual school
to justify their own evaluation of whether «just
interest»is present.
In the evaluation of whether a just interest is
present, one must first consider whether the use of
AbleCenter® AC-02 and AC-03 is
«necessary», i.e. whether the purpose for using
AbleCenter® AC-02 and AC-03 can be achieved in a
less intrusive manner. Having considered whether
the measures are «necessary» one must conduct an
evaluation and balancing of interests between the
school's desire to use AbleCenter® AC-02 and
AC-03 and any negative privacy consequences for
the affected pupils and teachers. Special
consideration must be made for cases where the
affected are under age.
Is a data processing agreement necessary?
During the use of AbleCenter® AC-02 and AC-03,
AbleCon AS does not store any personal data on
behalf of their users/customers. AbleCon only
processes the following data to ensure good
customer support and correct invoicing:
• Name of purchaser, order number and reference
number.
AbleCon AS is data processing controller for the
processing of this data and it is not necessary for
our customers or dealers to enter into a specific
data processing agreement with us.
Contact us
AbleCon AS
Trudvangveien 67
3117 Tønsberg, NORWAY
reg. nr. 916151764 Tel: +(47) 40 08 20 11
[email protected] | www.ablecon.no
reg. nr. 916151764 Tel: +(47) 40 08 20 11
[email protected] | www.ablecon.noAbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Privacy policy
AbleCenter® AC-02 and AC-03
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Data controller is Ablecon AS (Norway) and AbleCenter VisioSales AS.
We do not collect contact information from the user of AbleCenter® AC-02 and AC-03. We only collect data necessary for correct invoicing and customer support.
AbleCenter® AC-02 and AC-03 is developed with
privacy as base principle. We have implemented a
number of security features to protect the collected
data.
Here you can find out more about data we collect,
security measures we implement and which rules
apply when NAV aid centres, private persons,
companies, organisations, schools, or municipalities
purchase AbleCenter® AC-02 and AC-03.
Personal information (GDPR). When AbleCenter® AC-02 and AC-03 is in use, a direct video feed is transmitted from the AbleCenter-device to a dedicated AbleCenter app/ software that the pupils and employees use on their PC, tablet or mobile phone in the same room/ classroom. This means that the network is local inside the building in the same way as any home network. The AbleCenter network is not used to access the Internet or connect to other servers or networks. The AbleCenter network is only used for transmitting the video feed from the AbleCenter-device to the users' PC or tablet at the desk in the same room. The video feed is end-to-end encrypted, to ensure that no-one else than the user of the AbleCenter app/software gains access to what happens in the classroom. At the outset the video feed can not be save, neither by AbleCon As, the user or others. However, if this feature is needed, it can be activated by AbleCon AS.
We gather only name and contact information
about our customers, which for instance can be
NAV aid centre, school, organisation or
municipality. We usually do not know who the
user of AbleCenter® AC-02 and AC-03 is, but only
who the AbleCenter device was purchased by. If
Ablecon AS is given the job of installing and provide basic training in the use of our system,
our specialists will, as a result of this know who
the user is, but this information is not saved
anywhere at Ablecon AS All future follow/up and
training is delivered based on orders from the
purchaser of the system, for instance NAV aid
centre or school/educational facility. The
AbleCenter software/app collects only data
necessary for customer support and correct
invoicing.
Data that is collected:
The information is only related to the AbleCenter®
AC-02 and AC-03 serial number and purchaser, and
it is therefore not possible to identify who the
software/app user is.
Data can at any time be deleted upon request by
sending an email to [email protected].
Embedded PRIVACY To safeguard the privacy of users and people connected to the system, and ensure the video feed is as secure as possible, we have implemented a number of security measures. Some examples include:
• The system can be switched off and on with the enclosed remote control unit.
• End-to-end encryption of video feed.
• Possible to save up to 9 fixed positions/camera angles and zoom levels.
• Possible to lock the camera to 9 fixed positions (educational objectives).
• Possible with wire connected communication and control via the electrical grid.
• The system can be limited to only one active user at a time.
Password protected login for AbleCenter software.
• Password protected login for wireless network.
• Possibility to record video feed is deactivated as standard (can be activated when needed).
• «Take picture» function active as standard. Can be deactivated by the educator/administrator.
• Choice of server and security
Specialists and technical personnel at AbleCon AS
sign a duty of confidentiality and have access to
the information mentioned above. The
information is never transferred to third parties
except our data processors, unless as a result of
compulsory legal requests. AbleCon will notify
the registered persons by requests for information,
unless specifically stated in the legal procedures
that notification is illegal.
AC-03-device clearly indicates when the system
is on and a user connected.
When the system is switched on a red lamp lights
up on the AbleCenter-device. When a user is
connected to the AbleCenter® AC-03, a green lamp
lights up on the AbleCenter-device so that
everyone around can see that the system is active.
AbleCenter® AC-02 and AC-03 can be switched
off.
If use of AbleCenter® AC-02 and AC-03 is not
required, the device can be switched off by the
enclosed remote control. This limits the danger of
compromising the security of the system.
End-to-end encrypted video feed.
The video feed that is transmitted between the
AbleCenter device and the AbleCenter software/app
on the PC/tablet, is end-to-end encrypted. This way
we ensure that outsiders can not gain access to the
video feed.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Possibility to save up to 9 fixed positions.
AbleCenter® AC-02 and AC-03 can save up to 9
fixed positions/camera angles and zoom level using
the numbered buttons 1-9. By selecting the number
of desired setting, the camera moves automatically
to the saved position and saved zoom level. This
happens so fast that it is practically impossible to
interpret the image from one position to another. By
using fixed positions it is of course not possible to
receive other information than that which is located
within the saved position
Possibility to lock the system to 9 fixed positions.
AbleCenter® AC-02 and AC-03 can be locked to
fixed positions/camera angles that are saved and
approved by the educator/administrator
beforehand. This prevents user at home or outsiders
from receiving images outside the pre-set fixed
areas
Possibility for wire-connected communication
and control through the electrical grid.
If you do not wish to use the local wireless network
to control the system and direct the video feed, this
can be managed through a simple component that is
plugged into a wall socket which communicates
with a small unit plugged into the network port of
the PC. This makes it impossible for intruders to
gain access to this line, and the need for more
internal networks is eliminated.
One user.
The device can only be connected with one user at a
time through a fixed IP-address, but it is possible to
open up for more if required. Be aware, that this
reduces the security level of the system by some
degree.
Password protected login for AbleCenter software.
In order to use the software/app for AbleCenter®
AC-02 and AC-03 the software must be activated
with a code from Ablecon AS.
Password protected login for wireless network.
In order to manage the system through the wireless
network, one must log into an end-to-end encrypted
network med SSID and password.
Nothing is saved.
AbleCenter® AC-02 and AC-03 is used in real time.
The possibility to save the video feed is deactivated as
standard, but can be activated by contacting
AbleCon AS.
AbleCenter® AC-02 and AC-03 can be compared to a
pair of binoculars that offer the chance for a person
with vision impairment to see required positions in
the classroom to take part in the education process
on equal terms with other pupils and, to a certain
extent, participate in the social life in class.
The «Take picture » feature is active as standard but
can be deactivated by contacting AbleCon AS
Your rights.
You have the right to ask for insight, correction and
deletion of your personal information. Du may also
complain to the Norwegian Data Protection
Authorithy.
Personal data (GDPR).
Ablecon AS has conducted some research in
connection with our camera systems for vision
impaired pupils that have become very popular in
Norwegian school. We have studied the regulations
from NDPA connected to duty of information by the
use of a camera in the classroom.
As we have also developed a system that can transmit
video feed outside the building and home to home-based pupils (AbleCenter® AC-03 with home
control module) where we use systems that transmit
images and sound from the classroom to a
homebased pupil, we felt it necessary to to properly
investigate responsibility and privacy issues. This
was completed as part of a pilot-study preceding the
development of AbleCenter® AC-03 with home
control module.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
We conducted a thorough mapping, mainly
through web-based tools. We found a lot of
information but in this connection we would refer
to a statement from the Ministry of Knowledge
dated 19.05.2017
The statement is regarding the use of robot with
the possibility of two-way transmission of sound
and one-way transmission of video from the
classroom to a pupil based somewhere else. This
robot is designated AV1 and in the statement is
referred to as either «robot» or «AV1».
We must here underline that this statement is
regarding the use of robot with the possibility of
two-way transmission of sound and one-way
transmission of video from the classroom to a
pupil based somewhere else.
This means that the data feed is sent outside the
building and would therefore probably demand
more in relation to privacy and security than
AbleCenter® AC-02 and AC-03 which only
communicate between two devices locally in the
same room. Regarding AbleCenter® AC-02 and
AC-03 we are therefore uncertain whether the
Personal Information Act applies to the systems.
Camera based tools for pupils with vision
impairment, both distance camera and closeup
camera have been a natural part of classrooms,
where there are pupils with vision impairments,
for a number of years already. As far as we are
aware, these systems have not resulted that the
Personal Information Act has been applied
during all these years.
We would still always refer to this statement,
though, as it looks like areas covered by the
Personal Information Act must be adhered to by
the school or workplace.In situations where this equipment is used for the
school/education facility to fulfill its teaching
obligations, it is the education facility that has
processing responsibility for the processing of
personal data.
The way we interpret the statement
from the Norwegian Data Protection Authority, it
seems to cover the use of a system with the
possibility of two-way transmission of sound and
one-way transmission of images from the classroom
to a student who is in another place, where the
student can control the movement of the system and
thus image sections and communicate with audio
via network access. Where the purpose is for the
student to be able to take part in the school's and
school owner's educational process, the processing
of personal data is not carried out for private
purposes, but for training purposes. The Personal
Information Act then applies and the school owner
is responsible for processing, and must fulfill the
obligations according to privacy regulations. The
fact that the Personal Information Act applies,
means that the school owner must ensure that the
criteria in the Act are fulfilled.
Amongst other things, the Act stipulates criteria for
basis for data processing, for instance acceptance
(Personal Information Act §8 and §9) and
information to those affected by data processing and
storage (Personal Information Act §19) etc. As data
processing responsible the school owner has, in
addition, a number of obligations connected to
internal control and information security (Personal
Information Act §13 and §14).
From our point of view, this appears initially to be
about providing good and accurate information and
also collect user consent by the use of such tools. We
have therefore developed written materials that
make the information process easier for the school
and work place. This information can be
downloaded from our web page at
www.ablecenter.no/personvern.
If use of the system involves the use of the school
owner's network, the school owner must, among
other things, decide what risk it entails to allow the
use of ICT equipment on the school's network over
which the school owner himself has no control. This
assessment will be the same as for all other
equipment (PCs, tablets and smartphones etc.) that
staff and pupils use on the school's network, and
which the school owner does not control.
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
In higher education it is normal that the students
already at matriculation, have signed adequate
consent forms regarding this. Adequate
information to affected parties is critical.
By different uses in professional work life, this
should be investigated closer by the employer.
Frequently Asked Questions (FAQ).
Below we have gathered answers to the most
common questions.
When an educational facility/municipality has
purchased and started using AbleCenter® AC-02
and AC-03, they must ensure that the criteria in
the Personal Information Act are met.
What does the NDPA say.
The Norwegian Data Protection Authority stated
the following about cases where a robot with the
possibility of two-way transmission of sound and
one-way transmission of images from the classroom
to a student who is in another place, where the
student can control the movement of the system
and thus image sections and communicate with
audio via network access, is used. Where the
purpose is for the student to be able to take part in
the school's educational process, the processing of
personal data is not carried out for private
purposes, but for training purposes. The Personal
Information Act then applies and the school owner
is responsible for the processing, and must fulfill
the obligations according to the privacy regulations.
The NDPA also stated the following about cases
where AV1 (This robot has the designation AV1
and is referred to in the statement as either
"robot" or "AV1") is purchased by the school/
municipality in 2017 :
"The school owner must ensure that the
requirements in the Personal Information Act are
met. Among other things, the Act requires a basis
for processing, e.g. consent (Personal Data Act §8
and §9) and information to those affected, etc.
(Personal Information Act §19). As data
controller, the school owner also has a number of
duties related to internal control and information
security (Personal Data Act §13 and §14)."If use of the system means use of the school owners
network, the school owner must consider the risk
involved in allowing the use of ICT equipment that
the school owner does not control.”
Information to affected parties.
It is good policy to inform affected parties, but it is
up to you how this is done. We have developed two
draft information sheets where one is sent to
teachers and pupils and the other can be sent to
parents and next-of-kin at home.
Data processing basis.
This is a short summary of a longer evaluation of
the data processing basis. Contact us by email to
[email protected] if you want to receive complete
evaluation document.
Consent.
Consent from all pupils, teachers and others that
may come into contact with the AbleCenter device
during use, is one possible way for schools to
ensure a valid data processing basis. Consent is
though, but one of several alternative data
processing bases defined in the Personal
Information Act. Since AbleCenter® AC-02 and
AC-03 is also used by children, consent might be
unsuitable as data processing basis. Consent from
children is not considered valid, and it would
therefore be necessary that parents or legal
guardians give consent on behalf of the child.
Justified interest.
Schools may also process personal data if there is a
defined «justified interest».
It is AbleCon's evaluation that AbleCenter® AC-02
and AC-03 is designed in a privacy friendly way
which at the same time fulfills an important
purpose, namely to ensure that pupils with vision
impairments can take part in education on equal
terms with their class mates.
The use of AbleCenter® AC-02 and AC-03 is a good
tool for meeting the criteria for adapted education,
as set out in the Education Act (Education Act
§1-3)
AbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011
Based on this, it is the opinion of AbleCon AS that
a clear «justified interest» exists for schools to start
using AbleCenter® AC-02 and AC-03. It is still,
though, the responsibility of the individual school
to justify their own evaluation of whether «just
interest»is present.
In the evaluation of whether a just interest is
present, one must first consider whether the use of
AbleCenter® AC-02 and AC-03 is
«necessary», i.e. whether the purpose for using
AbleCenter® AC-02 and AC-03 can be achieved in a
less intrusive manner. Having considered whether
the measures are «necessary» one must conduct an
evaluation and balancing of interests between the
school's desire to use AbleCenter® AC-02 and
AC-03 and any negative privacy consequences for
the affected pupils and teachers. Special
consideration must be made for cases where the
affected are under age.
Is a data processing agreement necessary?
During the use of AbleCenter® AC-02 and AC-03,
AbleCon AS does not store any personal data on
behalf of their users/customers. AbleCon only
processes the following data to ensure good
customer support and correct invoicing:
• Name of purchaser, order number and reference
number.
AbleCon AS is data processing controller for the
processing of this data and it is not necessary for
our customers or dealers to enter into a specific
data processing agreement with us.
Contact us
AbleCon AS
Trudvangveien 67
3117 Tønsberg, NORWAY
reg. nr. 916151764 Tel: +(47) 40 08 20 11
[email protected] | www.ablecon.no
reg. nr. 916151764 Tel: +(47) 40 08 20 11
[email protected] | www.ablecon.noAbleCon AS | PRIVACY
Product models AbleCenter® AC-02 and AC-03
Product version: 2.1 | Updated 31.03.2023
Contact info: www.ablecon.no | [email protected] | support tel: +47 400 82 011