Sweden's data-protection authority ran a 2023 sandbox pilot with Stockholm's Traffic Office, testing whether LiDAR sensors counting women, men and children in public squares are lawful under the GDPR and Camera Surveillance Act, publishing its legal findings in February 2024.
Details
Maturity
Established
Promoter
Integritetsskyddsmyndigheten (IMY) with City of Stockholm Traffic Office, IoT Sverige and Kista Science City AB
Period
2023-2024
Region (NUTS)
SE11
Keywords
data protection, IoT, urban safety, regulatory guidance
Context
Sweden's data-protection authority IMY established a regulatory sandbox in 2022 to give organisations dialogue-based guidance on applying data-protection law to specific innovation projects.
Objectives
The second sandbox pilot, run in summer and autumn 2023, aimed to clarify whether LiDAR sensors and an AI classifier that estimate the gender and age of people crossing public squares are lawful under Sweden's GDPR and Camera Surveillance Act.
Activities
IMY worked with the City of Stockholm's Traffic Office, IoT Sverige and Kista Science City AB on a project using LiDAR sensors to build 3D point-clouds and classify people as women, men or children, testing the hypothesis that squares visited by more women and children are perceived as safer.
Results
IMY found it highly probable that the LiDAR/AI output constitutes personal-data processing under GDPR, and that the sensors are typically covered by the Camera Surveillance Act when a public authority operates them in a public place, even though no identifiable images are stored. It published its full reasoning in a report and webinar on 9 February 2024.
Conclusions
The sandbox delivered legal clarity, not a deployment authorisation -- IMY did not exempt the Traffic Office from GDPR or camera-surveillance rules, and after two completed pilots IMY made the sandbox a permanent institution later in 2023 with a widened mandate and recurring project rounds.
Implementation
Indicative cost
Low (< €50k)
Time to results
Short (< 1 year)
Staffing & skills
Integritetsskyddsmyndigheten (IMY), City of Stockholm Traffic Office, IoT Sverige, Kista Science City AB
Conditions for success
Dialogue-based regulatory sandbox structure enabling in-depth guidance rather than a simple yes/no approval
Multi-partner project design combining a public agency, an innovation cluster and a science-park operator
Public reporting of legal reasoning building institutional trust and transferability
Common failure modes
Sandbox produced legal clarity but not a deployment green light, leaving the Traffic Office's own compliance decision unresolved