Is black box data (EDR data) personal data?
Nick - Driven Forensics • 27 March 2024

Personal data, not personal data, let's take a look

Is BLACK BOX data PERSONAL DATA?

Two top tips to help identify whether the data is personal.

Modern vehicles capture around 25 gigabytes worth of data every hour and within such a sizeable information store, some of that information is likely to be personal data.

The Information Commissioners Office (ICO) has a definition of personal data, which can be found here:
https://lnkd.in/eFRmiEC9

Here's our top tips for identifying whether the data you have captured, is personal or not.

1. Is it personal?
Starting with the most obvious, can the information you have directly identify a person, if so, it's personal. That is the easy one.


2. Indirect identification
Unlike personal information, indirect information are effectively a list of clues. From those clues could you or others identify an individual from those clues? Clues can include places a person regularly goes, employee identification numbers and phone numbers etc. The easier you can connect the dots and identify someone, the more likely the data is to be personal.

Our experience in the vehicle systems forensics field over the past seven years has taught us the need to make an assessment on every case. We need to understand what information is being sought, what information may be gained unintentionally, what data is considered personal as well as implementing measures to minimise the capture of data that does not relate to the subject or our intended purpose.


It is never as simple as accessing collision data or other vehicle borne data. First of all, we need to assess what data might be there, which of the data we might collect has nothing to do with the subject we're trying to access data on and whether there are any unintended consequences of accessing such data.


Contact us today to discuss this further.


t. +44 (0)113 534 8708 | e. enquiry@drivenforensics.co.uk | w. www.drivenforensics.co.uk

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