The Article 29 Working Party has published an Opinion 9/2011 on the revised Industry Proposal for a Privacy and Data Protection Impact Assessment Framework for RFID Applications. It can be read in full here.
This is a follow-up Opinion to the partial endorsement of the original Framework. The Article 29 Working Party were concerned (in Opinion 5/2010) about:
- the absence of a clearly defined risk assessment approach
- insufficient consideration given to RFID tags carried by persons beyond the operational perimeter of the application
- the need to find a way to explicitly address the tag deactivation principles in the retail sector that are established in the European Commission’s Recommendation on the implementation of privacy and data protection principles in applications supported by radio-frequency identification.
The Working Party sought revisions to address these concerns and now endorses the revised Framework. But some of the comments from the Working Party as to areas of concern as RFID develops in concrete applications are well worthy of note.
