The GDPR Applied to Brain Corporation Robot Data

Brain Corporation (“Brain Corp”) is a technology company that engages with original equipment manufacturers to enable autonomous mobile machines. The Brain Corp BrainOS® software platform (“Software”) currently enables certain floor cleaning and delivery robots (each a “Robot”) by providing autonomous navigation, operational support, development, and fleet management. This paper discusses the manner and type of data collected by Robots, whether this data constitutes “personal data” under the EU General Data Protection Regulation 2016/679 (“GDPR”), and what measures Brain Corp has taken to protect this data from misuse and identifiability.