Letter from the Article 29 data protection Working Party to Claude Moraes, Chair of the Civil Liberties Committee (LIBE)

The letter expresses substantial concerns over the scheme.


EU-PNR: Substantial reservations expressed in: Letter from the Article 29 data protection Working Party to Claude Moraes, Chair of the Civil Liberties Committee (LIBE) (pdf) with detailed Appendix.

"First, the necessity of an EU PNR scheme still has to be justified. Precise argumentation and evidence are still lacking in that respect. Further restrictions should also be made to ensure that the data processing is proportionate to the purpose pursued, in particular considering that the report now includes intra-EU flights in the data processing...

the scope of the offences concerned should be further reduced and the retention period shortened and clearly justified....

the WP29 insists on the necessity to present as soon as possible a detailed evaluation of the efficiency of the PNR scheme. A sunset clause should also be inserted into the directive to assist in ensuring periodic review of the necessity of the system....

to reduce the list to the crimes for which the use of PNR data would effectively prove necessary for the police investigators and, in any case, to justify, for each category of crime currently listed, that the use of PNR data is necessary for the prevention, detection, investigation and prosecution of these crimes....

at the very least, philosophical belief, trade union membership, health data and sex life should be added to the list of data on the basis of which no decision producing adverse legal effects, such as regarding preassessment of passengers, must be taken."

 

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