Machine translations by Deepl, 2 September 2017: 'Tax authorities did not have licence plate photo management in order for years'

The Tax Administration's handling of privacy-sensitive licence plate photos was technically and organisationally flawed in recent years. Data irrelevant to the tax authorities on millions of license plates were not deleted for years.

This is according to documents released at the request of the ANP.

At internal memos (pdf) states that "no cleaning" took place of the annual 1 million licence plate photos collected by the tax authority itself using camera cars with automatic licence plate recognition (ANPR). "The photo data and metadata are still available from 2010".

According to the Data Protection Act, such data cannot be kept longer than necessary. It was only late last year that the tax authorities cleaned up these files once. The Inland Revenue acknowledges that the retention was unjustified.


Meanwhile, the collection and use of the licence plate photos has stopped and the data has been destroyed. This happened after the Supreme Court ruled early this year that there was no legal basis for using the licence plate photos to prove private use of company cars.

According to the judges, there was systematic collection of data on vehicle movements.

In a response, the Inland Revenue said that "at the time of the Supreme Court ruling, a structured process for the systematic destruction of non-relevant ANPR data was in preparation". The service also said that the stored data was "always secured according to the applicable guidelines".


Privacy First is critical and speaks of an "accumulation of illegalities". Apart from the lack of a legal basis and the storage of non-relevant data, the privacy organisation's Vincent Böhre said the "organisational mess" was also unlawful.

Officials concluded in recent years that management was "not properly invested and set up". There were ICT problems and makeshift systems. Management was not located in the right departments. Moreover, a lot of work had to be done manually and there was a lack of expertise and fixed practices. As a result, management of retention periods was not done structurally, but only ad hoc.

This was also the case with the many millions of photos the tax authorities obtained from police ANPR cameras. Non-relevant data here were deleted within two weeks, but potentially useful licence plate photos (52 million out of 130 million per year) were kept for several years."

Source: , 2 September 2017.

See also