Guidelines 1/2020 on processing personal data in the context of connected vehicles and mobility related applications

Section 2.3  Relevance and data minimisation

67. To comply with the data minimization principles, vehicle and equipment manufacturers, service providers and other data controllers should pay special attention to the categories of data they need from a connected vehicle, as they shall only collect personal data that are relevant and necessary for the processing. For instance, location data are particularly intrusive and can reveal many life habits of the data subjects. Accordingly, industry participants shall be particularly vigilant not to collect location data except if doing so is absolutely necessary for the purpose of processing (see discussion on geolocation data above, in section 2.2).