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

Subparagraph 3.1.2.4  Information and rights of data subjects

124. Prior to the processing of personal data, the data subject shall be informed according to art.13 GDPR, in a transparent and understandable way.

125. The data subject must be specifically informed of the available means to exercise his or her right of access, rectification, restriction and erasure. Since, the data collected in this context are provided by the data subject (through specific forms or through his or her activity) and processed on the basis of art.6 (1) (b) GDPR (performance of a contract), the data subject is entitled to exercise his or her right to data portability. As emphasized in the guidelines on the right to data portability, the EDPB strongly recommends “that data controllers clearly explain the difference between the types of data that a data subject can receive through the rights of subject access and data portability”.