People counting and the GDPR

Is people counting GDPR compliant? That depends less on the counting than on where the camera image goes. What the regulation requires, what Vicodis processes inside the camera and what it never stores.

This page explains our architecture. It is not legal advice — the assessment for your site is made by your data protection officer.

Vicodis stores
  • Counts per line and time interval
  • The number of people inside
Vicodis never stores
  • Images, video or faces
  • Identities, tracks or licence plates
The rules

What the GDPR actually requires

The GDPR applies to personal data: information relating to a person who is identified or can be identified. A camera image in which people can be recognised is personal data. A figure such as “318 entries between 9 and 10 am” is not — no one can be identified from it.

In data protection, visitor counting therefore comes down to three questions: which step touches personal data, for how long, and what comes out of it. Two principles of the regulation point the way:

  • Data minimisation (Art. 5): process only what the purpose needs. Counting needs a number, not an image.
  • Data protection by design (Art. 25): build the system so that the protective setting is the only possible one, not an option.
The image

Where the image is processed

In Vicodis the image is analysed inside the camera by AXIS Object Analytics. It exists only in the camera’s working memory for the moment of analysis. What reaches Vicodis is not a picture but an event: “one more crossing of line 1”.

In server-based video analytics the video stream travels over the network to another machine, and the image is processed there. That difference is explained in detail in on-camera counting compared to server-based video analytics.

The short analysis inside the camera is still processing in the legal sense. Whether it needs a notice or an entry in your records is for your data protection officer to judge — the architecture keeps it as short and as contained as technically possible.

Inside the camera
1 · Imageanalysed in memory, not stored
2 · Object“person crosses line”
3 · Eventcounter + 1
4 · Vicodisstores the count only
The difference

Why on-camera counting is not CCTV analytics

CCTV analytics works with recorded or streamed video. Vicodis has no video to work with.

No recording

Vicodis writes no images and no video, not even for a moment, not even on error.

No live picture

The dashboard shows numbers and charts. There is no video view inside Vicodis.

No tracking

No person is followed through a building or recognised again at another door.

No biometrics

No faces, no age, no gender, no other features of a person are derived.

The data

What Vicodis stores and what it never stores

Anonymous counting: personal data never reaches the database on the camera.

Stored on the cameraNever stored
Entries and exits per counting line and five-minute intervalImages, video, snapshots
The current number of people insideFaces, biometric features, age or gender
For vehicles: counts per vehicle classLicence plates
Capacity, line names and other settingsTracks, IDs or re-identification data
Report and alarm settingsPhone, Wi-Fi or Bluetooth identifiers

Count data cannot be deleted from the dashboard by accident or on purpose: deletion needs a one-time key that we issue on request. That protects the figures you use in reports and funding applications.

Paperwork

DPIA and signage

A data protection impact assessment (Art. 35) is required where processing is likely to result in a high risk to people. For DPIA people counting questions, the decisive facts are that the image never leaves the camera and that only aggregated counts are stored. Your data protection officer makes the call, taking national lists into account.

  • A short notice at the entrance is good practice: a camera counts visitors anonymously, no images are stored, plus a contact.
  • An entry in your records of processing activities, if your data protection officer sees processing in the camera step.
  • A description of the data flow for your files — we provide it on request.
Staff

Questions a works council will ask

Can it monitor staff?

No. Vicodis does not know who someone is. Employees walking through the door are counted like everyone else, as a number.

Can someone watch video through Vicodis?

No. The app has no video view. The camera’s own video functions are separate and controlled through the camera’s user accounts — they can be restricted or switched off.

Can attendance times be derived?

No. Without identities there is no way to tell when a particular person came or left.

Who can see the figures?

Whoever has a user account on the camera. Access is managed by your IT, not by us.

More on keeping all data in the building: people counting without cloud, server or internet. Classification under the EU AI Act: regulatory classification of an anonymous counting system. The product: Vicodis Visitor Counter.

FAQ

Questions about data protection

01

Is people counting GDPR compliant?

It can be, and the architecture decides. When the image is analysed inside the camera and only counts leave the analysis, no personal data is stored or transmitted. Vicodis works exactly this way. Your data protection officer still assesses the short processing step inside the camera and whether a notice at the entrance is needed.

02

Do I need a DPIA for anonymous people counting?

Usually not, but your data protection officer decides. A data protection impact assessment is required where processing is likely to result in a high risk to people. Counting that aggregates inside the camera and stores no images or identities is generally regarded as low risk, but national lists and your specific site can change the answer.

03

Can the camera still record video while Vicodis counts?

Vicodis itself never records or shows video. The Axis camera has its own video functions, which are independent of the app and controlled through the camera’s user accounts. If no one should see images, restrict or switch off video access in the camera settings; counting keeps working without any video stream.

How many visitors does your entrance really have?

Tell us your camera model or your project — we check compatibility and come back with a concrete proposal.