People in view: a 360 tour and the GDPR

With a 360 capture there is no outside the frame: the camera captures the entire sphere, including the colleague walking past behind the camera, the monitor with an open file on it and the noticeboard with the rotas pinned to it.

That makes it less a matter of being careful while photographing and more a matter of preparing the space before photographing. It is the same reason a shooting day in an empty building is not only more pleasant but also faster.

That does not mean it cannot be done. It means you do it properly: ask in advance and not on the shooting day itself, make clear that saying no has no consequences, record where the imagery will be used and for how long, and make sure someone can withdraw their consent later. That last part is a right, so you also need to know what then happens to that viewpoint.

For most tours, by the way, this is a problem you can skip. An empty room shows the room better, and that is exactly what you wanted to show.

Post and parcels with address labels, and personal belongings on desks that make someone directly identifiable.

The practical approach is a walk through the building before the shooting day, asking: what here would I not want on my website. That walk takes half an hour and saves hours of retouching afterwards.

• Screens. An open mailbox, a patient file, a customer list. In a panorama 20,000 pixels wide that is readable when you zoom in, and that is precisely the quality you paid for.
• Paper on desks, whiteboards and noticeboards. Names, rotas, phone numbers.
• Number plates in the car park. They are traceable to a person and belong among the things that have to come out.

If you publish to Google Maps, Google does its own blurring pass on faces and number plates. Do not rely on it blindly: that processing is designed for street imagery and is not flawless in indoor spaces. Whatever has to come out, you remove before it is uploaded.

Anonymising means someone can no longer reasonably be identified, not just that their face is a smudge.

Article 50 of the European AI Act requires that imagery of a real place that has been generated or edited with AI, and that could pass for real, is disclosed as such. That disclosure has to be clear, and be there at the latest the moment someone first sees the image.

With us it sits in the image itself, not underneath it. The future tour carries the label in every furnished view and shows the disclosure on the first visit, before you look around. The empty room in the 3D viewer also says in the image that AI emptied it.