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Privacy First demands privacy-friendly public transport chip card at Lower House

On Thursday 28 February next, the House of Representatives (standing committee on infrastructure and the environment) will host an important General consultation on the public transport chip card venue. In preparation for this General Consultation, Privacy First Foundation today brought the following points to the attention of relevant MPs:

  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, i.e. 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 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. Compulsory checking in and out for students with a student public transport chip card violates the right of students to travel freely and anonymously. Compulsory checking in and out for students should therefore be abolished.
  4. The planned "closing of the gates" at NS stations represents an unnecessary restriction of freedom of movement and could lead to dangerous situations in case of emergencies. It also creates insecurity in individual cases, for example children, the 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 incurs huge costs for travellers, whether they buy it, forget to check out, have a defective card or check-out post, or wish to travel anonymously with a paper ticket. Privacy First would like to hear from your Chamber and the responsible minister what measures will be taken to make travelling with a public transport chip card more affordable while maintaining privacy.