Guidelines 1/2020 on processing personal data in the context of connected vehicles and mobility related applications
Subparagraph 18.104.22.168 Legal basis
119. When the data is collected through a publicly available electronic communication, art. 5 (3) of the “ePrivacy” directive applies.
120. Because this is an information society service, art. 5 (3) of the “ePrivacy” directive does not require consent for gaining access to information that is already stored in the vehicle when such a service is explicitly requested by the subscriber.
121. For the processing of personal data and only for data necessary for the performance of the contract to which the data subject is party, art. 6 (1) (b) GDPR will be the legal basis.