Radio frequency identification (RFID) refers to a microchip technology that enables objects to be detected without contact. These chips are scanned and supplied with energy by means of a radio transmission technology. The data obtained, e.g. on products, can be automatically transmitted to a downstream IT system. This technology is seen as a complement to barcode technology, known from labels or imprints on food and consumer goods, or is used, for example, in access and theft protection, in customer cards or in the automotive industry for immobilizers.
Critics fear that as RFID becomes more widespread, personal data may be collected unnoticed and without the consent of those concerned, or linked to objects. In extreme cases, it could even be possible to derive usage or movement profiles. For this reason, data security and the protection of the right to informational self-determination are important issues with regard to the introduction of this technology.
Our law firm can support you on the subject of RFID with the following services:
- Expert opinions regarding data protection aspects of the use of RFID
- Review of various use cases for the application of RFID, e.g. RFID in discounters, RFID in the automotive industry, RFID in logistics, etc.
- Use of RFID in access control and time recording
- Advice on the use of RFID in compliance with data protection regulations
- Examination of technical-organizational measures for the use of RFID
- Consulting on the use of pseudonymization and anonymization in the use of RFID
- Preparation of information letters for customers, employees, suppliers, etc.
- Preparation of the required register of processing activities (VVT)
- Creation and conclusion of order processing contracts with external service providers
- Carrying out the legally required data protection impact assessment
- Creation and technical implementation of an erasure concept when using RFID
- Legal advice on the collection, processing and use of personal data using RFID
- Creation of a company policy, works agreement or service agreement on the use of RFID
- Performance and behavior control in the context of the use of RFID
- Creation of work and organizational instructions for employees on the use of RFID
- Creation and implementation of data protection and IT security training on RFID