Privacy Statement: Remote Sensing

Notification of processing of personal data

Last updated: 23 August 2022

Port of Antwerp-Bruges NV (public limited company) under Public Law (hereinafter "Port of Antwerp-Bruges", "we" or "us") attaches great importance to the protection of personal data. Personal Data are all the information about an identified or identifiable natural person (hereinafter the "data subject", "you", or "your"). 

We will always protect your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or GDPR) including any applicable current or future national or international legislation implementing or replacing the GDPR (hereinafter collectively "Applicable Privacy Legislation"). 


This notification on the processing of your personal data (hereinafter "Privacy Statement") was drawn up to clearly inform you about the processing of your personal data and your rights as a data subject.


As such, please read this document thoroughly and contact us if you have any questions via the contact details in section 9 below.

1. Application of this statement

This privacy statement applies to the processing of personal data of the following categories of data subjects:

  • The owners of passenger cars, vans, trucks and buses which drive past a remote sensing detector which registers their number plate.

2. Data controller

2.1 The controller for this processing is Port of Antwerp-Bruges.


2.2 The Data Protection Officer of Port of Antwerp-Bruges can be contacted at

3. Overview of the processing ((Personal) data, purpose, legal basis)

Only technical data are collected, as shown exhaustively in the table below.


Because each number plate not only has technical, but also personal data of the vehicle owner linked to it, it is theoretically possible to retrieve personal data. To avoid this, and to comply with the GDPR, we take specific measures when cross-referencing the different datasets. The combination of location, time and vehicle data potentially makes specific identification possible, which would constitute processing of personal data, which is subject to the rules of the GDPR. We therefore work with different data tables that can be cross-referenced with different unique "identifiers", but never with all "identifiers", thereby ensuring anonymity:

  • Dataset from the Remote Sensing campaign: the measurement results with and without location, time-stamp and vehicle identifier (VIN/number plate)
  • DIV vehicle identifier (VIN/number plate)
  • CarPass: usage data (kilometre reading in past years) and vehicle identifier (VIN/number plate)


Where necessary for analysis, we cross-reference the necessary data "double-blind", working with a unique token that anonymises the combination of location, time-stamp and vehicle identifier. The analyses are then only made with the data fields relevant to the analysis, meaning that the unique identifiers are unknown.


In other words, the initial data processing that Transport & Mobility Leuven does on behalf of Port of Antwerp-Bruges (and for which there is a processing agreement between TML and Port of Antwerp-Bruges) ensures that the processed data for the analysis, which is partly carried out by the subcontractor ICCT and partly by TML, is no longer privacy-sensitive.


Finally, to ensure that the data is completely anonymised (i.e. that there is no longer any possibility of "recovering" certain data because no one holds the key), the hash is not passed on with the processed data to the subcontractor ICCT.

Personal data

Date of first registration (month and year only)05/2017
Vehicle typePassenger car, light-commercial, bus, truck, motorcycle, etc.
Vehicle UNECE CategoryM1, N1 class II, M3, etc.
Purposetaxi, ambulance, etc.
Number of seats5, 45, etc.
Fuel typediesel, gasoline, ethanol, gas
StandardEuro 4, Euro 6b, Euro 6d-TEMP
ManufacturerFAW, Volkswagen
Engine displacementcm3 (cubic centimeter)
Number of cylinders3, 4, 6, etc.
Type-approval CO2 or fuel consumption4/km or l/100km
Model nameVita, Golf
Model year2017
Maximum powerkW
Mass in running orderkg
Technical permissible masskg
Emissions controlThree-way catalyst, Diesel Particulate filter
Powertrain technologyInternal combustion engine, Hybrid, Plug-in hybrids, Battery electric


  • The technical data behind the retrieved number plate, along with the vehicle's remotely measured emissions, are used to verify that the vehicle in question meets the emissions standard with which it was put into circulation.
  • The personal data, which come along with the technical data requested, are not used: see "4. Source of personal data".

Legal basis

The processing is necessary for the performance of a task in the general interest, namely improving the air quality in and around the Port of Antwerp. This is done by taking stock of the actual emissions performance of the fleet of vehicles driving in and around the port, and by issuing official reports to vehicle owners who are stopped by enforcement agencies because excessive emissions have been identified from their vehicles via remote sensing.

Insofar as the processing of personal data constitutes a contractual or legal obligation and the data must be provided by the data subject, the data subject is required to provide the personal data.

4. Source of personal data

4.1 Port of Antwerp-Bruges only processes personal data originating from another source, namely:

  • the Crossroads Database Vehicles of the Directorate General of Road Transport and Traffic Safety: all relevant vehicle data (year of manufacture, Euro standard, fuel type, etc.) and vehicle identier (VIN/number plate).


These are combined with:

  • dataset from the Remote Sensing campaign: the measurement results with and without location, time-stamp and vehicle identifier (VIN/number plate)
  • CarPass usage data (kilometre reading in past years) and vehicle identifier (VIN/number plate)

5. Categories of recipients

In accordance with Applicable Privacy Legislation, your personal data may be shared with:


5.1 In the context of this processing, your personal data will be passed on to third parties within the EU, namely Transport & Mobility Leuven, which processes the technical data on behalf of Port of Antwerp-Bruges, and immediately destroys the accompanying personal data.


5.2 Port of Antwerp-Bruges makes the necessary arrangements with each third party to whom the personal data are passed on and, if necessary, concludes a processing agreement with these third parties. Port of Antwerp-Bruges selects only those processors that offer the necessary guarantees with regard to data processing and data protection.

6. International transfers.

Your personal data will not be transferred outside the European Economic Area.


If you would like more information, please contact us at the following email address:

7. Retention period

7.1 Port of Antwerp-Bruges shall retain your personal data for as long as is necessary for the purposes set out in Section 3. After that the personal data shall be deleted. Specifically, these data will be retained for no longer than the duration of the project, i.e., in principle, no more than six months after they are collected.


For more information you can always contact

8. Your rights as a data subject

In accordance with the Applicable Privacy Legislation, you may exercise the following rights (if and to the extent applicable):

  • You can request access to and receive a copy of any personal data we have processed concerning you.
  • You can also request that your personal data that is incorrect or incomplete be corrected or completed.
  • You can request that your personal data be deleted.
  • You can object to the processing of your personal data, request that we restrict the processing of your personal data or request the portability of your personal data.
  • You can also object, free of charge, to the processing of your personal data for direct marketing purposes by contacting Port of Antwerp-Bruges at the address below or by using the unsubscribe link in any direct marketing communication.
  • If we collect and process your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of any processing based on your consent before it is withdrawn.


You can exercise these rights by sending an email to the following email address: We will handle your request in accordance with Applicable Privacy Legislation.


Finally, you also have the right to file a complaint with a supervisory authority.

9. Contact details.

Port of Antwerp-Bruges is responsible for the collection and use of your personal data as described in this Privacy Statement. You can contact us at


Contact details of the Data Protection Officer (DPO):

10. Updates to this Privacy Statement

We may update this Privacy Statement from time to time to comply with business, legal or technical developments. When we update our Privacy Statement, we will take appropriate measures to inform you, depending on the significance of the changes and the legal requirements in this regard.

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