V2X, and in general connectivity, enables additional means for potential exchange and collection of information that could be considered as “personal”. It is foreseeable that this kind of data will play an important role in development and operation of ADF, e.g., for error analysis.
Car users must be made aware of the fact that this information may be recorded outside of their vehicle, e.g. in another vehicles or cloud’s processing chain (Regulation (EU) 2023/2854).
Main Question
Is the car user which data is exchanged, made clearly aware of what type of information is exchanged via V2X and why (EC C-ITS Platform (2017))?
Sub-Questions:
- Are methods in place to provide confidentiality to the data exchanged via V2X that could be considered as “personal” for the ADS user?
- If not, are ADF designers aware about what personal user data could be recorded and stored by third parties when transmitted via V2X?
- Are methods in place to let the user know what data is shared and that this data can be recorded by third parties?
- If data may be recorded by third parties, is the user explained why, and is he allowed to provide an educated consent to share this data?
References
- EC C-ITS platform phase II (2017) Data Protection – Annex I – Processing personal data in the context of C-ITS. Available at: https://transport.ec.europa.eu/document/download/35a339a8-03e4-484f-9e63-1f14a192bb3c_en (Accessed: 12 February 2024)
- Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonised rules on fair access to and use of data and amending Regulation (EU) 2017/2394 and Directive (EU) 2020/1828 (Data Act). Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202302854 (Accessed: 12 February 2024)