FIA comments on data privacy provisions under UN Regulations including remarks concerning the work of the informal groups on automated driving (ITS/AD), automatic emergency calls systems (AECS), and automatically commanded steering functions (ACSF). The presentation covers issues such as protection of personal data, aggregation of data to protect individual identities, protection against unauthorized access (hacking), and prohibition against data use for purposes other than those specifically intended by a regulation. FIA proposes the deletion of data storage (DSSA) provisions under the draft texts for ACSF.
57. The expert from FIA presented GRRF-82-07 on data privacy and cybersecurity of (partly) automated driving and on Data Storage Systems for ACSF (DSSA). He advocated against potential DSSA installation requirements for data protection and cybersecurity reasons as, to date, no clarity would be provided on consumer protective measures. He stated that such systems could facilitate the collection (also over-the-air, outside of the vehicle) and interpretation of a large amount of data, that could easily be used against the driver, in various situations (e.g. for commercial, warranty, recall and liability purposes). He urged therefore GRRF to ban such systems as long as no fair and balanced relations among stakeholders would be guaranteed.