Published: 6 October 2021
The ODPA has been asked to comment on reports of a States of Guernsey proposed trial of a ‘black-box’ mileage tracker fitted in vehicles as an alternative to the current road tax regime, and what the data protection/privacy implications may be. Below is our comment in full, and we would like to thank the local media for seeking input on this topic at this early stage:
“The ODPA is not party to any details of this proposed trial, beyond what has been discussed in the media.
The Data Protection (Bailiwick of Guernsey) Law, 2017 provides a very clear framework for all activities where identifiable personal information is being collected or created. The States of Guernsey is required by law to involve its own Data Protection Officers in development of any proposed initiative like this, where personal data is being used, so that people’s rights under the law are built in from day 1 rather than bolted on as an afterthought. This is the principle of ‘data protection by design and by default’. In addition, the relevant States of Guernsey entity responsible for the proposed trial would have a legal obligation to perform a ‘data protection impact assessment’ (DPIA). DPIAs are an important tool for assessing the impact on the human beings whose data is being used. An effective DPIA also identifies any unintended consequences of the processing to ensure that steps are taken to reduce or eliminate risks to people.
Anyone handling the personal information of Bailiwick citizens has a clear legal and moral duty in respect of that data. This duty sits heavier on government as the data collection is rarely voluntary, and often has far-reaching implications for the citizen. It is therefore essential that the public are provided with full details of any initiatives such as this and that a full and open public discussion is had.”
The Bailiwick of Guernsey's independent supervisory authority which regulates data protection legislation. The ODPA protects people by driving responsible use of personal information through helping organisations get it right, deterring harmful information handling, and taking enforcement action against significant non-compliance
Receive regular information and statistics related to our activities and governance
Sign up nowReceive regular information and statistics related to our activities and governance
Sign up nowThe Office of the Data Protection Authority
+44 (0)1481 742074enquiries@odpa.gg
St Martin's House, Le Bordage, St. Peter Port, Guernsey GY1 1BR
Newsletters sign-up Data Processing Notice Careers Cookies
Website by & Indulge
© 2024 The Office of the Data Protection Authority.