DEDeutschENEnglish中文简体中文
Book a demo
Menu

Compliance

GDPREU AI ActCyber securityAutomotive overviewE-MarkISA validationOverviewPricing

Accounting

OverviewPricing

Growth

GrowthJoin the waitlist

AI infrastructure

OverviewModel trainingAnonymization modelData centerOn-premiseRobotics

Industries

Driving footage, anonymizedISA validationE-Mark for vehicle electronicsCE marking and market entry for robotsAccounting for Chinese-owned EU companies

Company

MissionTeamCareersNewsContact

Language

Book a demo

Compliance for the automotive stack.

Type approval, ISA validation, and the GDPR records and transfer documentation for test fleets and connected vehicle data. The agents draft; your team approves.

Talk to usRead the EU to China flow
Marsstein Compliance
Product demo, sample dataSample data
An approved transfer impact assessment for vehicle diagnostic data in Marsstein Compliance, on sample data.An approved transfer impact assessment for vehicle diagnostic data in Marsstein Compliance, on sample data.

The vehicle: ISA validation and type approval.

One place for the rest of the automotive stack.

The same buyer that anonymizes camera data also answers to OEM audits, the GDPR and the EU AI Act.

From recording to R&D abroad in three steps.

The order matters: nothing leaves the EU before the second step is done.

  • 01

    Anonymize in the EU

    Our anonymization model (AEON) masks faces and license plates in vehicle camera footage on EU infrastructure, before any copy leaves the EU.

  • 02

    Assess the dataset

    Blurring alone is not the test. GPS traces, lidar, timestamps and vehicle IDs are checked against singling out, linkability and inference, dataset by dataset.

  • 03

    Transfer with evidence

    Marsstein Compliance records what was masked, the assessment result and, where data stays personal, the Chapter V transfer mechanism and its supporting documents.

What Marsstein does, and what it does not.

Marsstein does mask faces and license plates in vehicle camera data with the anonymization model inside the EU, and record the per-dataset anonymity assessment and the transfer documentation in Marsstein Compliance.

Marsstein does not decide on its own that a dataset is anonymous, certify it, or replace legal advice. Your counsel or data protection officer signs off the assessment.

The anonymization model has processed 100+ TB of camera data.

How the anonymization model masks
Synthetic scene, masked by our anonymization modelSynthetic scene

Blurred is not the same as anonymous.

Anonymous data is outside the GDPR (Recital 26), and therefore outside the Chapter V rules on transfers to third countries such as China. That makes anonymizing before transfer the cleanest path, when it works.

It works only if the result is actually anonymous. Masking faces and license plates covers the obvious identifiers, but a GPS track, a precise timestamp or a vehicle ID can still point to one person. The Article 29 Working Party (Opinion 05/2014) sets three tests: can a person be singled out, can records be linked to them, can something about them be inferred.

The EDPB guidelines on connected vehicles (01/2020) point the same way: process data locally where possible, and consider anonymizing it before it is transmitted outside the vehicle.

Where data stays personal, Chapter V applies in full. China has no EU adequacy decision, so transfers need safeguards such as standard contractual clauses under Article 46. Regulators enforce this: in May 2025 the Irish DPC fined TikTok EUR 530 million in total, of which EUR 485 million for infringing Article 46(1) GDPR in its transfers of EEA user data to China.

The full flow, and the clauses

Primary sources

Every legal statement on this page rests on one of these documents.

Frequently asked questions

Your question is not listed? Ask us directly.

Talk to us
01Can we transfer vehicle camera data from the EU to China?
Yes, if the data is anonymous and therefore outside the GDPR, or if the transfer is covered by a Chapter V mechanism. China has no EU adequacy decision, so personal data needs safeguards such as standard contractual clauses under Article 46 (GDPR Articles 44-49).
02Is blurred video still personal data under the GDPR?
It can be. Blurring faces and plates covers direct identifiers, but GPS, lidar, timestamps and vehicle IDs can still single out a person, so each dataset is assessed against singling out, linkability and inference (WP29 Opinion 05/2014).
03Is anonymized data subject to the GDPR transfer rules?
No, anonymous data is outside the GDPR (Recital 26) and therefore outside Chapter V, but only if the dataset is actually anonymous after assessment. For pseudonymized data, the CJEU held in C-413/23 P (September 2025) that it may not be personal data for a recipient who cannot reasonably re-identify the people in it.
04Are faces and license plates important data in China?
Yes, for automobile data collected in China: the CAC Several Provisions on Automotive Data Security (in force 1 October 2021) list video and image data outside the vehicle containing faces and license plates as important data. Data collected in Europe and sent to China for processing is a different case, addressed by Article 4 of the 2024 cross-border data provisions.
05What does Marsstein do in this process?
The anonymization model masks faces and license plates in the camera data inside the EU, and Marsstein Compliance documents the assessment and the transfer. Marsstein does not certify that a dataset is anonymous and does not replace legal advice; your counsel or DPO signs off.

Planning to send test fleet data to R&D abroad?

Talk to us