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The policy authorizes collection of exterior vehicle camera and sensor images and video with consent or upon detection of a safety event, and separately authorizes collection of road information from exterior cameras at all times, with the acknowledgment that camera images may capture third parties in the surrounding environment.
This analysis describes what General Motors's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes two distinct collection triggers, consent-based and safety-event-based, for exterior camera media, and a continuous collection basis for road data derived from exterior cameras, with the acknowledged implication that third parties present in the vehicle's environment may be incidentally captured.
The updated statement narrowed its definition of personal information from 'identifies, relates to, or could reasonably be linked to you' to 'describes, relates to, or could reasonably be linked to you.' This language change affects which information GM must treat as personal information under the policy. The revised de-identification section reorganizes prior language, now stating GM 'may use technical measures to remove information that could reasonably identify you or your vehicle' and requires 'the same safeguards from any third parties we share it with.' The policy clarifies that its protections apply to personal information dealers disclose to GM, but do not cover dealers' independent data practices. Cruise is no longer listed as a GM affiliate exempt from this privacy statement, though the scope of privacy protections for Cruise users depends on whether Cruise now operates under this statement or maintains separate privacy terms.
View change record →The agreement authorizes collection of exterior camera images and video either with user consent or when a safety event is detected, and states that road information including signs and lane markings is collected from exterior cameras regardless of consent status; images may incidentally capture individuals in the surrounding environment.
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"We may collect images and video from your vehicle's external cameras and sensors (such as radar) only with your consent or when your vehicle detects a safety event (such as a collision or automatic emergency braking system engagement). You can change your consent anytime online in the Data and Privacy section of your GM account by logging in at OnStar.com or your vehicle's brand website. Exterior camera images and video may capture your surrounding environment and individuals incidentally nearby. We may collect road information from your vehicle's exterior cameras, such as signs and lane markings, even when images and video are not collected.Excerpt from General Motors's GM Privacy Statement
(1) REGULATORY LANDSCAPE: Collection of exterior camera images capturing third parties engages state biometric privacy laws, including Illinois BIPA if facial geometry data is derived from images, and Texas CUBI. The FTC Act applies to unfair or deceptive data collection practices. California CPRA may classify certain image-derived data as sensitive personal information. The continuous collection of road data from exterior cameras, even absent image or video capture, represents a data collection practice whose regulatory classification may vary by jurisdiction. (2) GOVERNANCE EXPOSURE: Medium. The safety-event carve-out for camera data collection without consent, combined with the continuous road data collection from exterior cameras, creates a data collection baseline that persists regardless of user consent choices. The incidental capture of third parties in exterior camera imagery creates additional governance obligations, particularly under state biometric statutes if image processing derives identifying characteristics. (3) JURISDICTION FLAGS: Illinois BIPA creates heightened exposure if exterior camera data is processed to extract facial geometry or other biometric identifiers from incidentally captured individuals. California CPRA's sensitive personal information framework may apply to image data. Washington's My Health MY Data Act may apply if camera data is used to infer health-related information. Any jurisdiction with a right of publicity statute may implicate collection of third-party images. (4) CONTRACT AND VENDOR IMPLICATIONS: Service providers processing exterior camera data are stated to have no independent right to use this data, which should be confirmed in data processing agreements. If image or video data is processed by third-party AI platforms for road analysis or safety applications, those processing relationships require assessment under applicable biometric and sensitive data frameworks. (5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the road data collection baseline from exterior cameras, which occurs regardless of user consent, is adequately disclosed and whether it satisfies applicable data minimization requirements. The safety-event carve-out for consent-independent collection should be evaluated against state laws requiring notice even in emergency data collection scenarios. Consent mechanisms for exterior camera data should be reviewed to confirm they meet applicable opt-in standards for states that require them.
This provision establishes two distinct collection triggers, consent-based and safety-event-based, for exterior camera media, and a continuous collection basis for road data derived from exterior cameras, with the acknowledged implication that third parties present in the vehicle's environment may be incidentally captured.
The agreement authorizes collection of exterior camera images and video either with user consent or when a safety event is detected, and states that road information including signs and lane markings is collected from exterior cameras regardless of consent status; images may incidentally capture individuals in the surrounding environment.
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