Privacy First input at Parliament debate on OV-chipkaart

Last week an important debate on the public transport chip card place. Although in the House of Representatives by now rise to abolish the OV-chipkaart altogether, Privacy First thinks it would be wise first and foremost to make the current OV-chipkaart more privacy-friendly. With that in mind, we gave the following points of interest to all members of the standing committee on Infrastructure and the Environment:

1. The 'anonymous' public transport chip card is not anonymous, as it contains a unique identification number in the RFID chip that allows travellers to be identified and traced retrospectively by linking transaction data. In Privacy First's view, this constitutes a violation of two human rights, namely freedom of movement combined with the right to privacy, or in other words the classic right to travel freely and anonymously in one's own country. Privacy First would like to hear from your Chamber and the responsible minister what steps have already been taken to introduce an anonymous OV-chipkaart that is truly anonymous, for example by developing new chip technology and modern forms of encryption without a unique identification number (privacy by design).

2. As long as there are no (real) anonymous OV-chip cards and anonymous discount cards, paper tickets (without chip) should remain available for travellers who want to be able to travel anonymously. Also, a 'pink' anonymous discount card for children and the elderly should still be introduced.

3. Mandatory checking in and out for travellers with a student OV-chipcard, a route card or annual season ticket serves no necessary purpose and should therefore be abolished.

4. The planned 'closure of the gates' at NS stations constitutes an unnecessary restriction of freedom of movement and can lead to dangerous situations in case of emergencies. It also creates insecurity in individual cases, for example children, elderly, sick or needy people who need to be escorted to the platform by family or friends. Privacy First therefore strongly urges to keep the gates open at all times or abolish these gates and replace them with anonymous check-in and check-out posts.

5. The current retention periods of OV-chipkaart data should be reduced to an absolutely necessary minimum. Also, travellers should be given the option to delete their travel history at any time.

6. The OV-chipkaart is costing travellers a lot of money, either when they buy it, or if they forget to check out, or if the card or a check-out post is faulty, or if they want to travel 'anonymously' with a paper chip card. Privacy First would like to hear from your Chamber and the responsible minister which measures will be taken to make travelling with a public transport chip card (or a new alternative to be introduced) more affordable while preserving and promoting everyone's right to privacy.