Before a people counter goes up at the entrance, someone in the organization will usually raise the data protection question. In many companies that is the data protection officer (DPO); in workplaces, employee representatives often want to know too. A camera-free counter makes the conversation shorter, but it still pays to arrive prepared. Here is what to explain, what to avoid saying, and what to put in the internal note.
A word on scope: this article describes how the WELLPOINT People Counter works. It is not legal advice, and the assessment of your own data processing stays with your DPO.
Start with What the Device Does
DPOs tend to value a plain, factual description more than a sales pitch. The essentials:
- The WELLPOINT People Counter, model Pulse V3, uses a time-of-flight (ToF) matrix sensor that measures distance with laser light.
- It is mounted beside the entrance, on the door frame or wall, 1.2 to 1.4 m above the floor, at a right angle to the walking direction.
- It counts entries and exits separately. WELLPOINT.cloud calculates occupancy as entries minus exits.
- It sends the counts over a secure connection using built-in mobile data, so there is no network cable and nothing to set up on your network. Wi-Fi is an option where the mobile signal is weak.
Then Say Clearly What It Does Not Do
This is the part that matters most to a DPO:
- There is no camera. The Pulse V3 does not capture images or identify visitors. Only anonymous entry and exit counts are transmitted from the counter.
- It cannot tell one person from another. It registers that someone passed and in which direction, nothing more.
- It sees the doorway only. It does not follow anyone after they have passed the entrance.
- Employees who use the counted entrance are counted like everyone else, as anonymous entries and exits. The counter does not distinguish staff from visitors.
The GDPR Wording to Use
When you summarize the device for the DPO, choose wording that is accurate rather than reassuring:
GDPR-friendly by design: no camera, no images, no identification of people – only anonymous entry and exit counts. Full GDPR compliance also depends on the specific data-processing context.
The second sentence is not a formality. Your context includes who has access to the WELLPOINT.cloud account, how you inform visitors and staff, and what happens to exported files. The dashboard account itself involves account data, such as the logins of the people who use it, so do not describe the whole setup as processing no data at all.
What to Put in the Internal Note
A one-page note usually covers what a DPO needs to start the assessment. Suggested contents:
- Purpose – why you count: for example staffing, opening hours, occupancy compared with your own permitted maximum, or conversion rate for shops.
- Device and placement – WELLPOINT People Counter (Pulse V3), time-of-flight sensor, no camera; which entrances, mounted beside the door at 1.2 to 1.4 m.
- Data from the counter – anonymous entry and exit counts only; no images, no identification of people.
- Transmission and provider – secure connection via built-in mobile data or Wi-Fi; WELLPOINT.cloud is provided by Involver System SRL, Romania, European Union.
- History – how far back the dashboard keeps counts depends on the plan: LITE one month, PLUS one year, PRO unlimited. Agree separately how long exported files are kept.
- Access and transfers – who in your organization has a WELLPOINT.cloud login, and whether CSV exports (PLUS, PRO) or the API (PRO) pass counts on to other systems.
- Information – how visitors and employees are told about the counter, for example a short notice at the entrance.
Talking to Employee Representatives
In workplaces, the same facts answer most questions from employee representatives. A camera-free counter is easy to explain to your data protection officer and employee representatives because there is nothing to show: no images exist. State plainly that the counts show how many people passed through a door, not who they were, and share the purpose from the internal note so everyone knows what the figures will be used for.
A Short Notice for the Entrance
Many organizations put a small sign at the counted entrance. Something along these lines works: “This entrance has a camera-free visitor counter. It counts entries and exits only and does not record images.” Adjust the wording with your DPO so it matches your own privacy notice.
Questions a DPO May Ask
- Is there any camera in the device? No. The Pulse V3 uses a time-of-flight sensor only.
- Who provides the service? Involver System SRL in Romania, European Union, which is both the manufacturer of the counter and the provider of WELLPOINT.cloud.
- Does it need access to our network? No. Built-in mobile data is included in every plan; Wi-Fi is optional.
- Can we see the dashboard before anything is installed? Yes, through a demo account that uses fictitious sample data.
If you want to show your DPO the dashboard before installation, request a demo account; it contains fictitious sample data only. The device and the plans are ordered on visitorcount.com, and more about the platform is on wellpoint.cloud.