As well as the new legislative framework, advances in technology in the last few years led to a huge increase in the amount of data, including personal data, generated by assets. For example, connected vehicles may contain information on an individuals’ location and driving style. A key priority for Leaseurope is ensuring that the specificities of the leasing and rental industries are recognised and taken into account in any guidance or interpretations regarding GDPR. In the context of connected vehicles for example, certain types of data which are considered personal in a traditional ownership model (such as data related to driving style) is not automatically deemed personal in a rented vehicle due to the high turnover of people driving the car and thus the inability to link that data to any one individual.
Another notable issue for the leasing and automotive rental industries relates to the rules for online payments, which fully entered into force at the end of 2020. The requirement for strong customer authentication (SCA) changes the way online payments are handled, requiring two forms of authentication for the vast majority of leasing and rental contracts that are carried out and paid for online.
- Ensure that national interpretations of GDPR and the e-Privacy Directive are consistent and take into account the nature of leasing and automotive rental business models
- Educate regulators like the European Data Protection Board (EDPB) in relevant areas such as data processing for connected vehicles and mobility related applications
- Help prepare the leasing and automotive rental industry for the change in how online payments will be processed, ensuring they understand well which elements are included and which are exempt