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Privacy Issues with Vehicle Event Recorders

Privacy Issues with Vehicle Event Recorders. Prof. Dr. Hansjürgen Garstka European Academy for Freedom of Information and Data Protection Berlin, Germany. Interests. Law Enforcement Accident Prevention Insurances Employers Research (Accident, Behaviour of Driver)

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Privacy Issues with Vehicle Event Recorders

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  1. Privacy Issues withVehicle Event Recorders Prof. Dr. Hansjürgen Garstka European Academy for Freedom of Information and Data Protection Berlin, Germany

  2. Interests • Law Enforcement • Accident Prevention • Insurances • Employers • Research (Accident, Behaviour of Driver) • Periodical Vehicle Testing • Rescue and Medical Requirements • Manufacturers

  3. Definitions • Vehicle Event Recorder (VER) • Journey Data Recorder (JDR) • Event Data Recorder (EDR) • Accident Data Recorder (ADR) • Incident Data Recorder (IDR) • Sensing and Diagnostic Module (SDM) • Passive Systems • Active Systems

  4. Previous Experiences • Tachograph (mechanical, digital) • SDM/EDR integrated in vehicle electronics, e.g. air bags, by OEMs • European Tests with ADR in Europeas fleet management tools

  5. Examples of Projects • eCall • Electronic Vehicle Identification (EVI) • Car2Car • On-Board Telematics Unit (OBTU) • Vehicle Event Recording based on Intelligent Crash Assessment (VERONICA) • American Commercial Vehicle Information System

  6. Fundamental Questions • Which data? • How collected? • Mandatory or optional? • How long stored? • Who has access?

  7. Data • Available: 16 000 specifications • Principle of necessity shows a wide varietyof data requirements regarding the different purposes • Crucial issue: data of drivers to be stored? • Video devices?

  8. Way of collection • Continuous recording (intervals?) • Event recording (how to define „event“?) • Triggering threshold

  9. Mandatory or voluntary? • Legal obligation in general • Legal obligation for specific vehicles (cf. tachograph) or specific groups (e.g. young adults) • Semi-mandatory (NHTSA) • Factual obligation by manufacturers • Factual obligation by insurances • Freely given and informed consent

  10. Retention time • JDR: Like telecommunications, long period for security purposes? Maybe, where appropriate, in specific cases? • Insurances: Pay as you drive • EDR: how much time to save history? • Depending on type of event?

  11. Access • Active Systems: Which institutions on which conditions? Informed consent necessary? Triggering by driver? • Passive Systems: Driver? Holder? Prosecution? Victims? Insurances? Manufacturers? • Organisational solutions: Only trusted third parties? Centralized Structures? • Information security: Encryption?

  12. Data Protection Demands • „No to the transparent driver“: Mandatory personalized storage of driver data only in connection with particularly dangerous situations (which?) • Voluntary installation by holder in other cases without storage of driver data (car rental, employees?). Therefore no use of (digitalized) driving licenses to start the vehicle. • Transparency regarding installation of VERs • No storage in central data bases • Protection against misuse • Legal regulation of data that must be stored, retention periods and access by third parties

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