Protection of personal data within FastPass
The FastPass project is committed to fully comply with the requirements on user privacy and the protection of their personal data when developing an Automated Border Control solution (ABC).
In order to ensure the most satisfactory compliance with the EU and national data protection regulatory frameworks, the consortium has adopted a multi-level approach supported by internal tools,procedures, external authorization and control:
Internal data protection coordination
A Data Protection Coordinator (DPC) has been established by the consortium. The tasks attributed to the DPC are the following ones:
- collect internal notifications of personal data processing operations directly related to FastPass project,
- manage the register storing the notifications,
- facilitate the liaison with national data protection authorities when it is requested by the other members of the consortium,
- provide advice on demand regarding the processing operations and their legal compliance.
Internal notification and registration
All processing operations of personal data within the project will be identified in advance and will be notified internally to the Data Protection Coordinator (DPC). A register listing all notification will be set up and maintained by the DPC.
In addition to this internal notification procedure, the FastPass members will respect their compliance and obligations with their respective national data protection legal framework.
External notification or authorization
The FastPass consortium will also identify the specific data processing operations which are subject to notification to or authorization by the national Data Protection Authorities (DPA).
External support and control
A Privacy Advisory Board (PAB) consisting of external experts will assist the FastPass in all matters related to privacy and data protection related matters. The role and duties of the PAB are:
- Support the consortium in privacy related fields
- Review the compliance of the research activities with legal regulations and social habits
- Advise the management board in critical cases with respect to privacy and ethics aspects.
The aim of the PAB composition is to have an overall and balanced view on privacy and ethics in border security. The reports by the Privacy Advisory Board will be forwarded to the European Commission.