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Interim Report on the EU Approach to the Commercial Collection of Personal Data for Security Purposes: The Special Case of Hotel Guest Registration Data

机译:欧盟关于安全目的商业个人数据收集方法的中期报告:酒店宾客登记数据的特例

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摘要

The United States (US) and the European Union (EU) have been, and in the future will continue to be, engaged in discussions on transatlantic exchanges of information, including personal information collected commercially but used for security purposes. There is widespread understanding of the US approach to privacy within the Federal government, including oversight of law enforcement, security, and intelligence agency use (collectively, security service use) of personal information, because of the accepted government practice of transparency within government. Far less is understood in the US about the EU approach to data protection and oversight within its security services. Pursuant to the Department of Homeland Securitys 2007 agreement with the Council of the European Union regarding the transfer of Passenger Name Record (PNR) data to the Department of Homeland Security (DHS) by air carriers operating flights between the US and the EU, the DHS Privacy Office recently published a comprehensive report on PNR. Mindful of this responsibility in 2007, the DHS Privacy Office looked for an analogous situation in which commercial entities collected PII for security service use. The DHS Privacy Office chose to investigate and report on the EU practice of collecting hotel guest registration data, as from a functional perspective it most closely mirrored PNR data collection and use. For comparative purposes, the DHS Privacy Office discusses PNR data within the report.

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