ROLE MODEL ANALYSIS Sample Clauses

ROLE MODEL ANALYSIS. The analysis is based on the following elements: ▪ EUROLINES is the end user (within the professional end user category) and the Data Controller under the Data Protection law, in all cases. As Data Controller, it has to fulfil relevant obligations as outlined previously, especially relating to the information of data subjects and notification. ▪ Application providers and SafeTRIP platform are considered as Data Processors, whose main obligations are security, confidentiality and acting only on the instructions of the Data Controller ▪ Only PP1 has been analysed ▪ Application providers are also Service Providers Case n°1 (Scenario n°1) ▪ First hypothesis: there is no Application or Service provider. The SafeTRIP platform operator collects ID number of SafeTRIP OBU and data location and forwards them to EUROLINES. The SafeTRIP platform operator processes only anonymous data. EUR-CS and EUR-OP link these data with those concerning coaches to handle delays, breakdowns and accidents. There is no restriction to adopt this role model. ▪ Second hypothesis: there are Application and/or Service providers which undertake coach tracking. The SafeTRIP platform operator collects data from the OBU and from EUROLINES; it addresses them to Application providers so as to handle services. This scheme means the SafeTRIP platform operator accesses personal data (those transmitted by EUROLINES: VIN number at least). Moreover, as there is no relationship between EUROLINES and the Application providers, all data must flow through the SafeTRIP platform operator which can be avoided in other scenarios. Case n°2 (Scenario n°2) Cases 2A and 2B present no difference from a legal perspective. However, if case 2A offers more flexibility in the choice of application providers, case 2B, by considering SafeTRIP consortium members as “preferred application providers”, offers competitive advantage. ▪ First hypothesis: the SafeTRIP platform operator provides only OBU and connectivity. An Application provider collects location data through dedicated coach tracking application. Several providers can be envisaged, one handling delays with EUR-CS and another handling breakdowns and accidents with EUR-OP. Each of them would collect data, through their own application for the provision of their own services. The SafeTRIP platform operator has no data and consequently does not fall under the scope of Data Protection law. The provider(s) collect(s) ID number of the OBU and data location and provide(s...
Sample 1
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ROLE MODEL ANALYSIS. In most cases, the end user is a physical person, even if some data collected through an emergency call can be used for other purposes and benefit to professional end user (e.g. data collected during an accident of Hazardous and Large Vehicle can be used both for helping driver and/or passengers and informing breakdown services). Case n°1 (Scenario 1) ▪ First hypothesis: there is no Application provider. The SafeTRIP platform operator collects ID number of the OBU, data location and Service Activation and forwards them to a professional end user. The SafeTRIP platform operator processes only anonymous data. The professional end user links these data with those concerning vehicles and handles eCall. Even if there is no restriction to adopt this role model regarding data protection aspects, we assume it will be difficult for each professional end user to conclude agreements with emergency services. If the end user is a physical person, the SafeTRIP platform operator has to provide data collection service and eCall service (sending emergency services in case of manual activation); this solution does not raise any problem. ▪ Second hypothesis: there is an Application provider which handles eCall service The same restrictions apply if the adopted scheme is similar to the one described in 5.2.3 – Case n°1 – 2° hypothesis. Another solution could be, while maintaining a contractual relationship between the SafeTRIP platform operator and the end user, to have an “operational” relationship between the Application provider and the end user: once the anonymous data are received from the SafeTRIP platform operator, the Application provider sends information to the end-user. This proposal would also apply where there is a physical end user. Cases n°2 (scenario 2) Neither of these eCall service models poses a problem from a data management perspective. However, as indicated previously, with a physical end-user, we may run the risk of a “conflict of applications”, without any prioritization. This could increase the liability of the SafeTRIP platform operator and/or the Application provider as they could potentially be challenged by the end user (considered as a consumer) for lack and/or bad information. Case n°3 (scenario 3) This scenario is typically one which has been adopted by PEUGEOT CITROEN AUTOMOBILES (French car manufacturers) in France, Belgium, The Netherlands, Luxemburg, Germany, Austria, Italia, Switzerland and Spain and by IMA-MAIF-MACIF for their French VCAL...
Sample 1

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