
Figure 1
Enablers of the evolution in drone use.
Table 1
Category of Sensors and Potential Privacy Impacts.
| CATEGORY OF SENSOR/PROCESSING | PAYLOAD/CAPABILITY | POTENTIAL PRIVACY IMPACTS |
|---|---|---|
| Optical Sensor (Cameras) | High-Definition Camera |
|
| Camera with zoom capability |
| |
| Audio Sensors | Directional Microphone |
|
| Environmental Sensors | Thermal Sensor |
|
| Multi-spectrum NDVI9 used to assess health of vegetation |
| |
| Gas Sensor |
| |
| Humidity Sensor |
| |
| Air Quality Sensor |
| |
| GPS/Geolocation Sensors |
| |
| LiDAR |
| |
| AI matching and recognition | Facial Recognition |
|
| ANPR |
| |
| Audio/Speech recognition |
| |
| General Platform Capability Concerns | First Person View | Risk of dehumanising data subjects arising from them being “othered” as collateral data capture not related to the primary focus of the processing. |
| Battery Endurance/Range | Out of sight, out of mind” risk. Drone platform could fly at altitude or in a flight range that risks more secondary capture of personal data than anticipated. |
Table 2
Recurring Data Protection Concerns for Drone Use.
| ISSUE | DESCRIPTION |
|---|---|
| Lawfulness, Fairness, transparency | A lawful basis must be found for the proposed processing activities which must be identified and laid out clearly. In the case of incidental data processing a lawful basis is often not even considered. Additionally, data processing is unlikely to be fair and transparent when individuals on the ground are unaware that a drone is in operation. Individuals on the ground must be made aware that their data is being captured. They should be informed of when, how, why, and by whom the drone is being used. This allows them to adjust their privacy expectations, be prepared and keep control over their privacy by acting accordingly. |
| Data Minimisation | Limiting personal data captured to only that which is necessary is difficult in the case of drone use where the desire to capture as much information as possible is common. |
| Integrity, Confidentiality, and Storage Limitation | Data taken from drones is not often labelled as personal data and thus is not kept in line with the storage requirements under the Storage Limitation and Integrity and Confidentiality principles of the GDPR. |
| Privacy of thoughts and feelings | Individuals have a right not to share their thoughts or feelings or to have them revealed. This includes beliefs or religious views which may be inferred from data captured by drones. |
| Chilling effect on behaviour. | Individuals may perform a form of self-preservation/self- censorship by restricting their behaviour when they are, or believe that they are, being watched. Making individuals in the area aware of the purpose of filming and what is being captured can reduce this negative effect. |

Figure 2
Drone Use Cases. Based on Mitka & Mouroutsos (2017).
Table 3
Taxonomy Level 1 Definitions.
| USE CASE TAXONOMY LEVEL 1 | DEFINITION |
|---|---|
| Monitoring and Measurement | Drone mounted sensors and associated technologies are used to monitor a location to gather actionable information about a thing/event or to support statistical measurement of an aspect of the environment, infrastructure, or services that are provided by the local authority. |
| Incident Response and Planning | Drone mounted sensors and associated technologies are used to support the planning for or response to incidents which may pose a risk to people, property, or the environment |
| Investigation and Enforcement | Drone mounted sensors and associated technologies are used to record and document information related to the detection, investigation, and prosecution of criminal offences or breaches of legislation |
| Media, Publicity, and Entertainment | Drone mounted sensors and associated technologies are used to capture audio-visual recordings of locations, incidents, or events. Drones may also be used to provide operational or logistical support to the production or execution of public events or entertainment. |
Table 4
Taxonomy of Drone Use: Levels 1 and 2.
| TAXONOMY LEVEL 1 | TAXONOMY LEVEL 2 | DEFINITION |
|---|---|---|
| Monitoring and Measurement | Environmental Monitoring | Use of drone mounted sensors and associated technologies to survey, monitor, or measure features of the natural environment to detect positive and negative changes in the environment and inform policy responses and remedial action. |
| Built Environment Monitoring | Use of drone mounted sensors and associated technologies to survey, monitor, or measure features of the built environment to detect positive and negative changes in the built environment, including impact on the natural environment and inform policy responses and remedial action. | |
| Population Movement Measurement | Use of drone mounted sensors and associated technologies to survey, and measure population movements within the area to support the development of and validation of statistical models to inform policy responses and remedial action. | |
| Surveying and Mapping | Use of drone mounted sensors and associated technologies to survey and map features of the natural or built environment for the purposes of producing geospatial and navigation data sets. | |
| Incident Response and Planning | Pre-Incident Planning | Use of drone mounted sensors and associated technologies to survey locations to identify issues and risks to be mitigated through the development of an incident response plan. |
| Event Monitoring | Use of drone mounted sensors and associated technologies to actively monitor an event to support event management and inform response to incidents at the event. | |
| Incident Response | Use of drone mounted sensors and associated technologies to support the response to an emergency incident event by the relevant agencies and to inform decision-making during the incident handling. Different categories of incident may require different technology responses. | |
| Investigation and Enforcement | Scene of Crime Response | Use of drone mounted sensors and associated technologies to assist the gathering of evidence and recording of information related to the scene of an accident or criminal incident to support the investigation of any offence and the prosecution of any offender. |
| Local Authority Statutory Function Enforcement | Use of drone mounted sensors and associated technologies to assist the gathering of evidence and recording of information related to the scene of a breach of regulations in an area which the local authority has a statutory investigative or enforcement role to support the investigation of any offence and the prosecution of any offender. | |
| Media, Publicity, and Entertainment | Media Recording | Use of drone mounted sensors and associated technologies to record video, audio, still imagery, or other data for publication or dissemination by the local authority or another party. |
| Event Production | Use of drones without any additional sensor technologies other than those required for the safe flight operations of the drone for the purposes of supporting the production of an entertainment event (e.g., drone-enabled light displays, event lighting, or equipment transport). |

Figure 3
Taxonomy Levels 1–2.
Table 5
Environmental Monitoring.
| TAXONOMY LEVEL 3 | DEFINITION | EXAMPLE RISKS AND MEDIATION |
|---|---|---|
| Algal Bloom Monitoring | Use of drone mounted sensors and associated analytics technologies to identify, map, and measure the extent of algal bloom outbreaks and inform planning around remedial actions | Acquisition of Data: Drone survey of an area using optical and hyperspectral imagery. Example Risk: overflight of homes or individuals in public or private areas while optical sensors are active and/or recording. Example Mitigations:
|
| Invasive Species Monitoring | Use of drone mounted sensors and associated analytics technologies to identify, map, and measure the extent of invasive species outbreaks and inform planning around remedial actions. | Acquisition of Data: Survey of an area using optical and hyperspectral imagery. Example Risk: Overflight of homes or individuals in public or private areas while optical sensors are active and/or recording. Example Mitigations:
|
| Wastewater Discharge Monitoring | Use of drone mounted sensors and associated analytics technologies to identify, map, and measure, the discharge of wastewater into the environment. | Acquisition of Data: Drone survey of an area using optical, multi-spectrum or thermal imagery. Example Risk: overflight of homes or individuals in public or private areas while optical sensors are active and/or recording. Example Mitigations:
|
| Waste Management Monitoring | Use of drone mounted sensors and associated analytics technologies to identify, map, and measure, the operation of approved waste disposal locations. This could include the use of gas sensors to measure emission of methane or other gases. | Acquisition of Data: Drone survey of an area using optical, multi-spectrum imagery or gas sensors. Example Risk: Risk of secondary capture of individuals visiting or working at the waste management facility. Example Mitigations:
|
| Air Quality Monitoring | Use of drone mounted sensors and associated analytics technologies to gather statistical data on air quality in an area. | Acquisition of Data: Survey of air quality in an area using drone-mounted pollution sensors. Example Risk: Use of optical sensors on drone for flight/navigation may capture imagery of homes/private areas or individuals in public or private areas. Example Mitigations:
|
| Noise Pollution Monitoring | Use of drone mounted sensors and associated analytics technologies to gather statistical data on noise pollution and ambient noise levels in an area. | Acquisition of Data: Survey of air quality in an area using drone-mounted microphones and audiometry sensors Example Risks:
|
Table 6
Built Environment Monitoring.
| TAXONOMY LEVEL 3 | DEFINITION | EXAMPLE RISKS AND MEDIATION |
|---|---|---|
| Building Safety Monitoring | Use of drones to survey buildings, particularly areas that are inaccessible or difficult to access without other safety equipment, to assess risks to public from defects or damage | Acquisition of Data: Survey of building using optical sensors (cameras) to capture high-definition images of features or defects. Might also include use of gas sensors to detect emissions or toxic gases. Imagery/sensor data would usually be recorded for inspection or to be shared with other stakeholders involved in remediation. Example Risks:
|
| Preventative Maintenance Planning & Monitoring | Use of drones to survey buildings or other built environment, particularly areas that are inaccessible or difficult to access without other safety equipment, to assess, identify, and prioritise requirements for preventative maintenance | Acquisition of Data: Survey of building using optical sensors (cameras) to capture high-definition images of features or defects. Might also include use of gas sensors to detect emissions or toxic gases. Imagery/sensor data would usually be recorded for inspection or to be shared with other stakeholders involved in remediation. Example Risks:
|
| Energy Efficiency Measurement & Monitoring | Use of drones to survey buildings or other built environment, particularly areas that are inaccessible or difficult to access without other safety equipment, to assess, identify, and prioritise requirements for preventative maintenance | Acquisition of Data: Survey of building using optical sensors (cameras) to capture high-definition images of features or defects. Might also include use of gas sensors to detect emissions or toxic gases. Imagery/sensor data would usually be recorded for inspection or to be shared with other stakeholders involved in remediation. Example Risks:
|
| Hazardous Material Storage Monitoring | Use of drones to survey buildings or other built environment, particularly areas that are inaccessible or difficult to access without other safety equipment, to identify any risks associated with the storage of hazardous or potentially hazardous materials. | Acquisition of Data: Survey of locations using optical sensors (cameras) to capture high-definition images of areas where hazardous or potentially hazardous materials are stored. Might also include use of gas sensors to detect emissions or toxic gases or LIDAR mapping of areas obscured by foliage. Imagery/sensor data would usually be recorded for inspection or to be shared with other stakeholders involved in remedial action. Example Risks:
|
Table 7
Population Movement Measurement.
| TAXONOMY LEVEL 3 | DEFINITION | EXAMPLE RISKS AND MEDIATION |
|---|---|---|
| Traffic Flow Measurement | Use of drones to survey traffic flow for defined short periods (statistical sampling) | Acquisition of Data: Capture of optical image data of vehicles to be analysed off-line using machine learning technologies or human inspection to generate statistical analysis of traffic flow. Example Risks:
|
| People Movement Measurement | Use of drones to survey pedestrian movements for defined short periods (statistical sampling) | Acquisition of Data:Capture of optical image data of vehicles to be analysed off-line using machine learning technologies or human inspection to generate statistical analysis of traffic flow.Example Risk:
|
| Surveying and Mapping | Use of drone mounted sensors and associated technologies to survey and map features of the natural or built environment for the purposes of producing geospatial and navigation data sets | Acquisition of Data: Capture of optical image data of landscape and landscape features. Example Risks:
|

Figure 4
Incident Response and Planning.
Table 8
Incident Response and Planning.
| TAXONOMY LEVEL 3 | DEFINITION | EXAMPLE RISKS AND MEDIATION |
|---|---|---|
| Accident/Emergency Response | Use of drones to assess scene of an accident or emergency incidents to provide information on the incident and associated risks. | Acquisition of Data:
|
| Missing Person Response | Use of drones to assist in the search for missing persons | Acquisition of Data:
Example Mitigations:
|
| Pollution Incident Response | Use of drones to assist in the execution of response to a pollution incident | Acquisition of Data:
|
| Fire Incident Response | Use of drones to assess scene of a fire safety incidents to provide information on the incident and associated risks. | Acquisition of Data:
|
| Hazardous Materials Incident Response | Use of drones to assess scene of emergency incident where there is a known or potential Hazardous materials risk to provide information on the incident and associated risks. | Example Risks:
|
| Pre-Incident Planning (Scene Survey) | Use of drones to survey a location in advance of an event or as part of a risk assessment and mitigation planning for a location. | Acquisition of Data:
|
| Event Monitoring | Use of drones to monitor crowd movements at events to provide feedback to event security and support personnel | Acquisition of Data: Survey of an event location using optical sensors and audio sensors to provide real-time information to event staff. Example Risk: High-definition video recording will capture identifiable people. Imagery may include data relating to health if injured persons are captured Example Mitigations:
|
| Equipment Transport | Use of drones at incidents or events to transport equipment to inaccessible or hazardous areas | Acquisition:
|

Figure 5
Investigation and Enforcement.
Table 9
Investigation and Enforcement.
| TAXONOMY LEVEL 3 | DEFINITION | EXAMPLE RISKS AND MEDIATION |
|---|---|---|
| Forensic Accident Scene Recording [Note: processing may be covered by Part 5 of Data Protection Act 2018] | Use of drones to conduct survey of an accident scene to support investigation process | Acquisition of Data: Survey of accident area using high-definition video/thermal imagery or other sensors Use of LiDAR or similar technologies for rapid mapping of incident area. Example Risks:
|
| Forensic Crime Scene Reporting [Processing is covered by Part 5 of Data Protection Act 2018] | Use of drones to conduct survey of an a known crime scene to support investigation process | Acquisition of Data:
High-definition video recording may capture identifiable people. Drone may overfly private homes or other private areas. There is a risk of secondary capture of personal data of bystanders if they are recorded. Example Mitigation:
|
| Waste Management Enforcement | The use of drone mounted sensors to carry out inspections of authorised and unauthorised waste management facilities and to gather evidence of any legislative or regulatory breaches. | Acquisition of Data:
|
| Planning Enforcement | The use of drone mounted sensors to carry out inspections of any building or development to assess compliance with planning permissions and gather evidence of any legislative or regulatory breaches. | Acquisition of Data:
|
| Pollution Enforcement | The use of drone mounted sensors to gather evidence to support prosecutions for pollution offences. | Acquisition of Data:
High-definition video recording may capture identifiable people. Drone may overfly private homes or other private areas. There is a risk of secondary capture of personal data of bystanders if they are recorded. Example Mitigation:
|
| Hazardous Materials Storage Enforcement | The use of drone mounted sensors to gather evidence to support the detection of and removal of materials and the execution of any criminal or administrative sanctions. | Acquisition of Data:
High-definition video recording may capture identifiable people. Drone may overfly private homes or other private areas. There is a risk of secondary capture of personal data of bystanders if they are recorded. Example Mitigation:
|

Figure 6
Media, Publicity, and Entertainment.
Table 10
Media, Publicity, and Entertainment.
| TAXONOMY LEVEL 3 | DEFINITION | EXAMPLE RISKS AND MEDIATION |
|---|---|---|
| Media Recording with focus on people | Use of drones to capture video, still images or footage of events or activities where the focus of the recording is an individual or a group of individuals with the intention of publication. | Acquisition of Data: Use of optical or audio sensors to record video, still images, or other audio-visual information. Acquisition of Data: High-definition video recording may capture identifiable people. Drone may overfly private homes or other private areas. There is a risk of secondary capture of personal data of bystanders if they are recorded. Example Mitigation:
|
| Media Recording with focus on location | Use of drones to capture video, still images or footage of events or activities where the focus of the recording is an individual or a group of individuals with the intention of publication. | Acquisition of Data: Use of optical or audio sensors to record video, still images, or other audio-visual information. Example Risk: Flight path of drone may overlook private homes or other private areas. There may be secondary capture of identifiable data subjects. Example Mitigation:
|
| Event Logistics | Use of drones to provide logistics/transport support for the execution of an event or publicity activity. | Acquisition of Data: Use of GPS and drone mounted sensors to support piloting of drone to required location. Record imagery for off-site analysis, incident response review, training. Example Risk: Video sensors will capture identifiable people or may capture footage of private homes or private locations. Example Mitigation:
|
| Event Performance | Use of drones to carry out a planned flight path as part of the execution of a performance activity. | Acquisition of Data: Use of GPS and drone mounted sensors to support piloting of drones in a defined flight path to execute a performance event. Example Risk: High-definition video recording will capture identifiable people. Imagery may include data relating to health if injured persons are captured. Audio sensors Example Mitigation:
|
