Version 1.0 – July 2025
Prepared by Minnovation Technologies

1. Introduction

This Privacy Impact Assessment (PIA) evaluates the collection, processing, and safeguarding of personal information by XVision Lite, a cloud-based video analytics system developed by Minnovation Technologies. It is intended to identify privacy-related risks, demonstrate how these are addressed, and confirm compliance with relevant Australian privacy laws and standards.

2. System Overview

XVision Lite enables remote AI-powered image analysis using static video or image uploads. It is commonly deployed in environments where real-time edge hardware is unavailable or impractical. Systems/Hardware submit images (e.g., still frames from video or snapshots) to a secure cloud service, where analytics models extract metadata and return results.

All processing takes place within a dedicated, isolated Azure Virtual Machine under Minnovation’s control. No continuous live video is streamed or stored.

Key features include:

• Object recognition and vehicle classification
• License plate recognition (LPR)
• People and cyclist detection
• Cloud-based reporting via AlphaX Cloud dashboard

3. Personal Information Involved

Submitted images may incidentally include:

• Vehicle license plates
• Facial features of individuals
• Visual representations of persons, vehicles, or location-specific identifiers

4. Legal and Regulatory Framework

Minnovation ensures that XVision Lite complies with:

• Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)
• Privacy and Data Protection Act 2014 (Vic) where applicable
• Notifiable Data Breaches (NDB) scheme

Client contracts specify privacy responsibilities, data control terms, and any jurisdiction-specific compliance obligations.

5. Data Flow and Architecture

Stage	Data Activity
Upload	Static image uploaded via secure browser session or API
Processing	AI model runs on isolated Azure VM instance
PII Handling	Blurring or low-resolution conversion of plates and faces before display
Output	Results (e.g., plate text, object metadata) returned to AlphaX Cloud
Storage	No image is retained beyond processing unless explicitly required by customer
Dashboard	Results visualized in blurred or anonymized form only

6. Privacy Measures and Safeguards

• Ephemeral Image Handling: Images are used for real-time analysis only and not retained by default.
• Privacy Masking: Faces and license plates are blurred or downsampled before any display or review.
• Secure Cloud Isolation: XVision Lite runs in a locked-down Azure environment with no external access.
• Encryption: SSL/TLS for all uploads; AES-256 for any temporarily held data.
• Access Control: Restricted to authorized users and support staff under audit control.

7. Privacy Risk Assessment and Mitigation

Risk	Likelihood	Impact	Mitigation
Exposure of PII during upload	Medium	High	TLS encryption, image not stored post-processing
Overcollection of identifiable data	Low	Medium	Visual masking and processing limits
Unauthorized access to cloud system	Low	High	Cloud firewalling, RBAC, MFA
User misunderstanding about data retention	Medium	Medium	Transparent data use policy, opt-in storage only

8. Roles and Responsibilities

• Customer (e.g., local government, private operator): Acts as data controller – determines purpose, data scope, and visibility of analytics.
• Minnovation: Data processor – operates the system securely and within legal/commercial boundaries.
• Privacy and Security Officer: Maintains documentation and enforces technical compliance.

9. Transparency and Public Communication

Minnovation encourages customers to:

• Notify affected individuals or the public when images are collected for analysis
• Publish privacy summaries when required
• Clarify that XVision Lite does not stream, archive, or profile individuals

10. Data Retention and Deletion

• Images are not stored unless specifically enabled for diagnostics or legal purposes
• Metadata is retained as per client policy
• Secure deletion processes ensure temporary files are removed promptly

11. Review and Audit

This PIA will be reviewed:

• Annually
• Following major product updates
• At the request of a client or regulatory body

12. Contact for Privacy Matters

Minnovation Technologies
Email: support@minnovation.com.au
Phone: 1300 916 082
Address: 11 Rays Way, Pakenham, VIC 3810 Australia