Privacy Notice - Euston Trial

Privacy Notice: Createc Ltd and the Department for Transport (DfT) trial crowd monitoring technology to improve public safety and security.

Createc Ltd (“We, “Us”) are partnering with the Department for Transport (DfT) on a trial (hereafter referred to as “The Trial”) of our proprietary crowd monitoring technology (hereafter referred to as The Technology). The Trial is being conducted with the DfT in connection with its public task to improve public safety at transport hubs.

The Trial will be conducted from 30th November 2021 – 31st March 2022 at Euston Station, with Createc Ltd and DfT as joint controllers of the data produced. For the duration of The Trial Createc Ltd will have control over the development, operation, and security of The Technology (both hardware and software) and the processing of the data.

We are committed to protecting and respecting privacy. The data gained from The Trial will be used only to develop The Technology, it will not be used to identify individuals.

Individuals will be represented as dots with a centre of mass (“centroids”). This ‘Pseudonymisation’ of data (defined in Article 4(5) GDPR) means we have replaced any information which could be used to identify an individual with a pseudonym, or, in other words, a value which does not allow the individual to be directly identified. Although Pseudonymisation means it is highly unlikely that an individual could be identified, as a precaution we will treat this data as personal data and have taken strict measures to ensure we comply with GDPR.

This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the data collected during The Trial will be processed by us. Shorter privacy notices will also be installed at Euston Station to alert the public.


  1. How to contact us about this notice

If you have any questions about this Privacy Notice or the use of your personal information during this trial, please go to the DfT website for guidance on all enquiries.

Queries about the processing of data should be addressed to


  1. What data are we collecting?

Pseudonymised data regarding movements of both individuals and crowds will be recorded for the duration of The Trial and used to develop The Technology.

The Technology generates raw data on the rough shape, height and width of an individual, to an accuracy of approximately 5cm. This information is processed in under a second to produce a dot (centroid) which represents each person (see Figure 1). The raw measurement data is not stored after processing, will not be used in this trial, and will not be accessible by Createc, Her Majesty’s Government, law enforcement agencies or any other party.

Figure 1. Each individual of the crowd is represented by a dot.

Movement “Tracks” are produced that capture the movements and trajectory of each centroid. The track data will consist of locations, direction, speed, velocity, dwell time, etc. of individuals.


  1. Why are we collecting this data?

A vast amount of people movement data is required to be collected to train The Technology to understand what ‘normal’ human behaviours are; to then train the system to identify abnormal (safety critical and/or security critical) behaviour. It is essential to have as much data as is possible to develop an effective system.

As required by GDPR, we have a legal basis for collecting this data under section 6.1 (f) Legitimate Interests. We justify this on the basis that:

  1. We are improving the management and safety of the space for the persons of whom we are collecting data. We are doing this with the minimum of data, and minimum of risk to privacy.
  2. We will not use the data for the purposes of identification of individuals, therefore the impact on the rights and freedoms of individuals is minimal and is significantly outweighed by the benefits of the research.
    • Data on individuals will not be searchable or extractable. It will not be possible to identify an individual from the thousands of centroids and movement tracks recorded at any point in time throughout The Trial.


  1. How do we store and process this data?

This trial will produce an enormous amount of raw data, and it is not practical to store or transmit this data. Instead, edge processing occurs in real time, within the hardware system to process the raw data into centroids which represent each individual; and tracks that show the movements of each centroid. The raw data is held in short term memory for less than one second whilst the edge processing occurs, after which the data is overwritten. No raw data which could be used to identify individual characteristics is stored for more than one second.

The processed data is not stored on-premise, the hardware system transmits the processed data to the Cloud via 4G. There is no public access to the installed hardware system or the data at any time.

Storage of the processed centroids/tracks data on the cloud is via servers and services which have successfully completed the ISO 27001 and SOC 1, SOC 2, and SOC 3 evaluation processes. These systems are used for a large percentage of UK and International commercial cloud-based software.

DfT and Createc Ltd have appointed Information Asset Owners (IAO) and DfT and Createc will be joint controllers of the data for the duration of the trial. After the trial completes and Createc complete their contractual requirements, DfT will cease the role of data controller. From this point forward Createc will be the sole data controller of the data generated from the trial.

Data will not be disclosed to a third party unless Createc Ltd or DfT are permitted or required to do so by law.


  1. How long will we store the data?

The data will be used to develop The Technology; therefore, the data is required to be stored as long as it is required for technology development. The data will be used to continuously develop The Technology in different ways – to iteratively improve performance. As the data is required for these scientific purposes only, the data will be kept as long as it is of scientific use, after which time it will be destroyed.


  1. Your data protection rights

The data is part of a pseudonymised data set. This means it will not be possible to identify, search or extract individual centroid/track from the data set.

It will therefore not be possible to request a record of, or to delete an individual’s data. This would require deleting all crowd data for the same period and doing so would render the data set severely compromised, wasting significant Government resource spent to collect the data.

If you have any concerns about the use of your personal information, please contact DfT using the details given in section (1) of this Privacy Notice.

Matt Mellor, CEO, Createc

Matt Mellor, Managing Director

Matt Mellor started his career as an academic working in research and development at Oxford University where his specialist field was in computer vision and robotics with medical application. But in writing papers, which he says were mainly “read by other academics so they could cite it in their research”, Matt could see there was a vital component missing.

“To turn that research into a product I learned that you have got to make that happen yourself to ensure others recognise the value of it,” said Matt. “That started me on an odyssey to learn about the full process of technological development. That means not just learning about technology, but also about business, people, finance – all the parts you need to make something happen which is going to make a positive change in the world.”

With that in mind, Matt moved to Cumbria and joined REACT Engineering. “REACT put the emphasis on entrepreneurship and I joined the company to apply what I had learned in nuclear medicine to nuclear engineering.” In particular, Matt was able to apply his knowledge in medical imaging to provide smart, technological solutions to the nuclear clean-up industry.

In 2007, Matt was the technical lead in setting up REACT’s own spin-out – aerial surveying company, Hi-Def, which gave him valuable experience of the process involved in setting up a spin-out business. Hi-Def went on to be a sustainable, successful business in its own right and in 2016 became part of the BioConsult SH group. Meanwhile, Matt set up Createc in June 2010, and as CEO has led the company to achieve impressive growth ever since.

Createc started out with just three members of staff – Matt, Alan Shippen and Pete Rodgers. The company’s mission was to create a profitable business out of computer vision and robotics research and development, demonstrating the value such a service adds to industry. Building on technological expertise in the nuclear sector learned from REACT Engineering, Createc developed its N-Visage® technology which went on to be used in the clean-up following the Fukushima Daiichi accident in Japan.

Closer to home, Createc used its intellectual property in computer vision to build a business opportunity and set up spin-out company, Sportlight. Earlier this year, it launched a second spin-out from its robotics expertise creating Createc Robotics.

Looking ahead, as society and industry move out of a Covid-19 lockdown, Matt sees robotics playing an ever more important role – but warns those who think it will be an overnight change, to be more patient. “Society has always overestimated what technological development will take place over a two to five-year period. But it has always underestimated what development will take place over 20 years,” said Matt.

“Technological development is an accumulation of small goals which build on top of each other. It creeps forward so that over a 20-year period people then look back and are amazed at how much the world has changed. In 20 years’ time we are going to have a lot more robots, and we will have improved collaboration between human and machine. In some areas that might involve helping to remove people from having to carry out tasks in hazardous environments. In other areas it might be giving people more senses and more capabilities.”

Createc applies its thinking and technologies to any problem to find a solution, and takes a flexible approach when doing so. This means that it can adapt for a range of industries and a range of situations. “We look at the way we can do something, not where we can do it,” said Matt. It’s an approach which has seen its solutions applied in a range of industries and settings, including nuclear and defence, rail and security. Among future growth areas for Createc are heavy engineering, major industrial and general construction.

Createc has received two Queen’s Awards in recent years, one for International Trade and one for Innovation, recognising the company’s success in developing technology. The company is also proud to have won awards for innovation from The Institution for Engineering and Technology (IET), The International Atomic Energy Agency (IAEA) and Nuclear Decommissioning Authority (NDA).

Createc’s strategy as it moves beyond its 10-year anniversary is to concentrate on research and development to launch a series of further spin-out companies. Two things Matt is keen to influence in the wider economy to help support the company’s ambitions are funding and leadership. “We need to make sure that the UK is more start-up friendly. And we need more entrepreneurs who want to come and run these businesses,” said Matt. “To me an entrepreneur takes complete ownership and picks their way forward and proceeds confidently in the face of doubt.”

“We have had a sustained growth rate of 40 per cent, and we are focused on continuing to grow at this rate. In the first ten years we have grown from a company with three people turning over £180,000 to 30 people turning over £3.5m. To sustain that level of growth by the end of the next ten years we would have 300 people turning over more than £60m.”

Matt has a clear vision of how the company will keep driving forward, and his motivation and appetite to lead the company to further success is clear. “My motivation comes from bringing something completely new to life which results in the world being a better place,” he said. “Seeing all the pieces come together and creating this thing which creates an economic benefit and also has a positive impact on the world is really satisfying.”