NOTE from: German delegation to: Working Party on General Matters, including Evaluations (GENVAL): Proposal for a Directive of the European Parliament and of the Council on the use of Passenger Name Record data for the prevention, detection, investigation and prosecution of terrorist offences and serious crime – German position (Council doc. 8118/11, LIMITE, 25 March 2011, pdf):
“Germany would like to thank the Commission for its efforts in preparing the dossier to which Germany attaches great significance in terms of both policy and fundamental rights. In particular, Germany notes that the present draft addresses several key concerns which Germany expressed regarding the Commission’s 2007 proposal for a Framework Decision:
· restricting its scope to international flights – Article 1 no. 1 of the draft,
· establishing a decentralized structure of central offices – Article 2 no. 1 of the draft,
· further reducing retention periods, in particular the period for storing full PNR data – Article 9 no. 1 of the draft,
· clearly specifying the different possibilities to process data – Article 4 of the draft.”