Privacy notice: Self-Driving Vehicle Trial


Five AI respects your privacy and is committed to protecting your personal data.

This privacy notice will inform you about how we will look after your personal data, your privacy rights and how the law protects you in relation to the information we obtain from you in connection with the self-driving vehicle trial in Five AI’s self-driving vehicles.

Certain information will also be collected about you by TRL, an independent company to Five AI that is carrying out research into autonomous vehicles as part of the self-driving trial. For the purpose of the self driving trial, Five AI and TRL are joint controllers of your personal data. TRL’s privacy notice for the self-driving trial can be found here.

1. Important information and who we and TRL are

The purpose of this privacy notice

Our general privacy notice can be found at It’s important that you read that information, together with this notice.

This privacy notice supplements our general privacy notice by giving you information about how the personal data that is obtained from you when you apply to trial a ride in a Five AI self-driving vehicle and thereafter. It’s not intended to override our general privacy notice.

In particular, this privacy notice explains the respective roles and responsibilities of Five AI and TRL in relation to your personal data as agreed between Five AI and TRL. Broadly, we are responsible for the provision and administration of the self-driving experience and TRL are responsible for conducting and reporting on the research.


Five AI Limited (referred to as, “we”, “us” or “our” in this privacy notice) and TRL Limited are joint controllers in respect of the personal data either we or TRL collect in relation to the trial and are responsible for it.

We’ve appointed a data privacy manager who’s responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights, please contact the data privacy manager using the details below.

TRL have also appointed a data privacy manager. The contact details for TRL are in their privacy notice.

Contact details

Our full details are:

  • Full name of legal entity: Five AI Limited
  • Name of data privacy manager: Claire Bennett, General Counsel Five AI
  • Email address:
  • Postal address: FAO General Counsel, Suite G4, Bristol & Exeter House, Lower Approach Road, Temple Meads, Bristol, England, BS1 6QS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We’d appreciate the chance to deal with your concerns before you approach the ICO, so please consider contacting us first.

Changes to this privacy notice

This privacy notice was created on 16 September 2019 and there are no historic versions.

2. The data we collect about you in relation to the administration of the trial and how it’s collected

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

In the sign-up questionnaire, invitation to book and non-disclosure agreement, we ask you to provide various information that is, on its own or when combined with other information, personal information. For example, your name, phone number and email address. We collect this data from you by you filling in and submitting the relevant form. We do not collect any other personal data from you in relation to these forms.

We may also collect information about you after you submit the sign-up questionnaire, from third party publicly available sources when carrying out eligibility checks, or directly from you over the phone or email e.g. when discussing any accessibility or mobility requirements you may have with you.

3. How we use this personal data

We ask for, process and retain your personal data so we can:

  • consider your application to trial a ride, including checking your eligibility, confirming your identity and, where you have accessibility or mobility requirements, exploring with you whether we can make the trial accessible to you
  • respond to your application and invite you to book a ride where your application is approved;
  • make the necessary arrangements for your ride, provide you with certain information in advance and inform you of any changes to these arrangements, including if the ride has to be cancelled for any reason;
  • answer your questions;
  • identify who took a ride and when, in order to be able to provide further information that might assist with the analysis of the research data (see section 5 for more information);
  • otherwise manage our relationship with you. This includes administering and exercising our rights under our non-disclosure agreement with you and retaining records for legal liability and insurance purposes.

Please note: Where you are participating in the self driving vehicle trial as an employee of the Direct Line Group, we will let the Direct Line Group know which slot you have booked for timesheet purposes.

Your information will be retained for as long as we need to retain it to carry out these purposes. For example, we will need to retain a record of who undertook a ride and when for insurance and liability purposes, and name and contact details to manage our relationship with you for so long as this remains relevant. In contrast, other data may not need to be kept after the conclusion of the trial and/or research.

The lawful basis for processing your data is that it’s necessary for our legitimate interests (conducting trials of autonomous vehicle technologies and enabling us and/or TRL to conduct research in connection with this to inform the development of autonomous vehicle technologies and services, and managing our relationship with you from these activities).

While we may ask for your consent to process your data, and do not collect it unless you consent, generally we do not rely on consent as a legal basis for processing your personal data.

4. The data that will be collected about you in relation to the research, and how this is collected

If you application to trial a ride is approved and you choose to book a ride with us, we will provide you with a participant ID.

You may be asked to complete written questionnaires before, during and/or after your self-driving experience and may be interviewed about your experience by TRL. Your answers will be recorded and stored by reference to your participant ID (i.e. pseudonymised).

5. How this research data will be used and how long it will be kept for

TRL is primarily responsible for analysing and reporting on this research data, although it is possible that we may also do some analysis. Information about how this data will be used by TRL and how long TRL will keep it for is in TRL’s privacy policy [insert link].

We and TRL will keep confidential any research data that on its own could be used to identify you personally except when the research team has your explicit permission to use it.

To assist in the analysis of the research data, we may wish to refer to our in-vehicle video footage and other data collected during the self-driving vehicle journey (our vehicles are equipped with internal CCTV systems focused on the driver and front passenger for safety and security - please see our general privacy notice for further information). It is unlikely that this video footage or data would contain your personal data. However, to provide them with this data we may need to use your participant ID and other personal data to identify the footage and data for the ride to which feedback relates.

TRL may provide us with a copy of their reports of any research that they produce relating to the trial.

We and/or TRL may want to communicate some of the research findings publicly, for instance in academic conferences and journal papers, press releases and at public events. If the findings are communicated, the content will be presented so that it is anonymous and cannot be attributed to any particular participant (except where you have given your explicit permission to share particular personal data).

Your information will be retained by us for as long as we need to retain it for the purposes of the research. The lawful basis for processing your data is that it’s necessary for our and TRL’s legitimate interests (conducting and enabling TRL to conduct research in connection with trials of autonomous vehicle technologies to inform the development of autonomous vehicle technologies and services).

While we may ask for your consent to process your data, and do not collect it unless you consent, generally we do not rely on consent as a legal basis for processing your personal data.

6. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the section headed ‘Your legal rights’ in our general privacy notice which explains what those rights are and how you can exercise them.

7. How we’ll communicate with you

When we have to contact you, we’ll do so using the contact details you’ve provided to us.

Please read this notice together with our general privacy notice, which you’ll find at It contains important information about, among other matters: changes of purpose; disclosures of your personal data; international transfers; data security; data retention; and, your legal rights.