German Federal Data Protection Commissioner publishes recommendations for connected cars

On 1st June, the Federal Data Protection Commissioner (DPC) published 13 recommendations (pdf, German) for the protection of personal data with regard to autonomous driving and connected cars.

Among others, the DPC recommends that it must be clear and apparent what kind of data is processed without the consent of data subjects. In practice, this means that privacy policies must be put in place at all time and data subjects (especially the driver but also other natural persons concerned) must have the possibility to inform themselves about the processed data.

The DPC also recommends that data subjects should have the possibility to access that information, for example via the display of the entertainment system of the car.

Car-to-Car communication may only encompass the personal data strictly necessary for the respective purpose. This recommendation also applies to data-based services. Furthermore, the DPC recommends that Car-to-Car communication must be adequately protected against illegal access by third parties, for example via encryption.

Additionally, car manufacturers should implement the principle of “Privacy by Design”. Cars (and the underlying systems) should be constructed in a way that users can choose and modify the settings of the system in order to minimize the processing of personal data and information about their driving behavior.

All of these recommendations are of course only this, recommendations. However, most of the points raised by the DPC can, in one way or another, be found in the current data protection legislation and the forthcoming General Data Protection Regulation.

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