The market of the so-called "connected vehicles" has
been considerably growing since 2015. According to a recent study
by AlixPartners, 78 million of connected vehicles will be
commercialized in 2018, generating a EUR40 billion turnover.
To operate properly, connected vehicles collect much personal
data, notably by connecting to drivers' phones. Aware of the
potential data protection issues that might arise, the French Data
Protection Authority ("CNIL") in March 2016 initiated
work on a compliance package ("pack de
conformité") for connected vehicles, which is to
be achieved next spring.
This compliance package, which is currently elaborated in
consultation with the automobile industry, and innovative companies
from the insurance and telecommunications sectors, as well as
public authorities, will contain guidelines on the responsible use
of personal data in connected vehicles.
On 3 October 2016, at the International Motor Show in Paris
("Mondial de l'Automobile"), the CNIL
provided an update on the progress of the compliance package for
The CNIL, which stressed that personal data issues should be
taken into account right from the design phase of the vehicles,
contemplated three different scenarios:
In-In scenario: Personal data collected within
the vehicle remains in that vehicle without external transmission
to a service provider
In-Out scenario: Personal data collected
within the vehicle is transmitted outside the vehicle to a service
provider in order to provide a service to the driver
In-Out-In scenario: Personal data collected
within the vehicle is transmitted outside the vehicle in order to
trigger an automatic action in the vehicle
The CNIL expressly encouraged market participants to favor the
In-In scenario, under which personal data is processed within the
vehicle without any external transmission to a service provider.
According to the CNIL, this scenario appropriately protects the
drivers' personal data, and will trigger softer obligations for
The CNIL also reminded the following:
First, all data that may be attributed to an identified or
identifiable individual, notably number plates or vehicle serial
numbers, is to be regarded as personal data subject to the French
Data Protection Act ("Loi Informatique et
Libertés") and the General Data Protection
Second, the compliance package aims to raise market
participants' awareness on the transparency and fair data
collection principles. According to the CNIL, those principles
command that personal data shall not be collected without at least
informing the data subjects, and even possibly seeking their
Third, the CNIL favors a "privacy by design"
approach, which will notably result in the implementation of easily
customizable dashboards, allowing the driver to keep control over
his personal data
The principles set out by the CNIL should ensure adequate
protection for personal data collected in connected vehicles, while
not inhibiting innovation in the automobile industry.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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