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EU: Comments on the EU-PNR (passenger name records), from European Travel Agents’ and Tour Operators’ Associations letter to Council Presidency
01 August 2008
European travel operators and travel agents' comments on the EU-PNR (passenger name record) system reveal strong reservations on the proposal: European Travel Agents’ and Tour Operators’ Associations letter to Council Presidency
(EU doc no: 12360/08, pdf).
Scope: the Framework Decision: "ECTAA considers that the proposal for a Framework Decision should only cover data for passengers on flight into and out of the EU. It is essential that it is not extended to intra-EU flights."
- Scope: "it is fundamental that data will not be used other than for border purposes"
- Costs: "This proposal will have significant technical, operational and financial consequences for carriers. Inevitably that cost will be passed on by the carriers to the end user, the passenger"
- so we will be paying for our own surveillance
- US demands: PNR data is currently transmitted to the USA after a flight departs. The USA demand for data 24 hours in advance and
immediately after flight closure is called "an uneccessary duplication"
. In addition: "Charter carriers in particular rarely receive such information in advance of 24 hours" and "To put in place an advance system for charter carriers would be costly and require considerable time as the current systems used by tour operators do not lend themselves to this."
: The Council working party has abandoned discussions on the Commission's proposal for an EU-PNR scheme and are going to start again drawing up their own proposal because a number of EU governments want to go much further. With the UK in the lead a number of member states want:
- the system to cover not just flights in and out of the EU but also flights between EU countries plus all flights within
- the system to cover not just all flights but all sea and land travel as well;
- the data and information gathered to be used not just for entry-exit but also for any law enforcement purpose.
See: Note from the Austrian delegation: EU doc no: 11724/08
Council Presidency Note: EU do no: 11281/08
and Council Presidency Note: 11772/09
plus penultimate draft of the proposal during discussions in the Council's Multidisciplinary group on organised crime: EU doc no: 7656/08 Rev 2