European Data Protection Supervisor
European Data Protection Supervisor



Publication EU Internal Security Strategy in Action: Five steps towards a more secure Europe

Friday, 17 December, 2010

Opinion on the Communication from the Commission "EU Internal Security Strategy in Action: Five steps towards a more secure Europe"

See also the text of the Communication from the Commission to the European Parliament and the Council - "The EU Internal Security Strategy in Action: Five steps towards a more secure Europe".

Publication Intelligent Transport Systems

Wednesday, 22 July, 2009

Opinion on the Communication from the Commission on an Action Plan for the Deployment of Intelligent Transport Systems in Europe and the accompanying Proposal for a Directive of the European Parliament and of the Council laying down the framework for the deployment of Intelligent Transport Systems in the field of road transport and for interfaces with other transport modes, OJ C 47, 25.02.2010, p. 6

The EDPS has adopted an opinion on the European Commission's proposed deployment plan for intelligent transport systems (ITS) in Europe that was adopted in December 2008 to accelerate and coordinate their deployment in road transport and their connection with other modes of transport. The deployment of ITS  has considerable privacy implications, for instance because these systems make it possible to track a vehicle and to collect a wide variety of data relating to European road users' driving habits.

The EDPS notes that data protection has been taken into consideration in the proposed legal framework and that it is also put forward as a general condition for the proper deployment of ITS. He however underlines that the Commission's proposal is too broad and too general to adequately address the privacy and data protection concerns raised by ITS deployment in the Member States. In particular, it is not clear when the performance of ITS services will lead to the collection and processing of personal data, what are the purposes and modalities for which data processing may take place, or who will be responsible for compliance with data protection obligations.

The EDPS opinion includes the following main recommendations:

  • clarification of responsibilities: it is crucial to clarify the roles of the different actors involved in ITS in order to identify who will bear the responsibility of ensuring that systems work properly from a data protection perspective (who is the data controller?);
  • safeguards for the use of location technologies: appropriate safeguards should be implemented by data controllers providing ITS services so that the use of location technologies is not intrusive from a privacy viewpoint. This should notably require further clarification as to the specific circumstances in which a vehicle will be tracked, strictly limiting the use of location devices to what is necessary for that purpose, and ensuring  that location data are not disclosed to unauthorized recipients;
  • "privacy by design" approach: the EDPS recommends to consider privacy and data protection from an early stage of the design of ITS to define the architecture, operation and management of the systems. Privacy and security requirements should be incorporated within standards, best practices, technical specifications and systems.

Background information
ITS apply information and communication technologies (satellite, computer, telephone, etc.) to transport infrastructure and vehicles with the intention to make transport safer and cleaner and to reduce traffic congestion. ITS applications and services are based on the collection, processing and exchange of a wide variety of data, both from public and private sources, including information on traffic and accidents but also personal data, such as the driving habits and journey patterns of citizens. Their deployment will also rely to a large extent on the use of geolocalisation technologies, such as satellite-positioning and RFID tags. As such, ITS constitute a "data-intensive area" and raise a number of privacy and data protection issues that should be carefully addressed in order to ensure the workability of ITS across Europe.

Publication Evaluation report from the Commission to the Council and the European Parliament on the Data Retention Directive (Directive 2006/24/EC)

Tuesday, 31 May, 2011

Opinion on the Evaluation report from the Commission to the Council and the European Parliament on the Data Retention Directive (Directive 2006/24/EC), OJ C 279/01, 23.09.2011, p.1

Publication Public access to documents

Monday, 30 June, 2008

Opinion on the Proposal for a Regulation regarding public access to European Parliament, Council and Commission documents, OJ C 2, 7.01.2009, p. 7

The Opinion reacts on the Commission's proposal aimed at reviewing the rules on public access to documents held by EU institutions. The Opinion focuses on an amended provision dealing with the relation between public access to documents and the protection of personal data. Although the EDPS welcomes the Commission's intention to clarify the delicate interaction between public access and data protection, he feels that the substance of the proposed amendment fails to provide the appropriate answer. He therefore proposes a different provision to stimulate discussions in Parliament and Council.


Publication Passenger Name Record

Friday, 25 March, 2011

Opinion on the use of Passenger Name Record data for the prevention, detection, investigation and prosecution of terrorist offences and serious crime, OJ C 181/02, 22.06.2011, p.24

Publication Combating fraud in the field of value added tax

Friday, 30 October, 2009

Opinion on the proposal for a Council Regulation on administrative cooperation and combating fraud in the field of value added tax (recast), OJ C 66, 17.03.2010, p.1

Publication Online manipulation and personal data

Monday, 19 March, 2018

Opinion on online manupulation and personal data.