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CIT data protection experts focus on issues relating to the transfer of passenger data for passenger claims

The protection of passengers' personal data is an important issue for railway undertakings. When passengers submit complaints such as reimbursement or compensation requests in the event of delays or train cancellations, personal data must be collected in order to respond to passengers' claims.

To take due account of data protection, CIT began some time ago to review the relevant processes in complaints handling, in particular the CIT Agreement on Claims Handling (“AIV”).

CIT therefore reviewed some processes in the AIV with the CIT data protection experts during a meeting in May this year and proposed adjustments where necessary. In particular, the passenger dossier process for international journeys with multiple carriers played an important role in the discussions. The question was discussed as to whether a carrier which receives a request from a passenger, but which is not the carrier responsible for processing the request, may forward this request and the passenger's details contained therein to the responsible carrier.

Different arguments were exchanged by the data protection experts regarding what the justification according to Article 6 GDPR might be to allow a carrier to forward the passenger's claim to another carrier that took part in the passenger`s travel chain.

The data protection experts also emphasized that the AIV should contain a stronger clause committing signatories to complying with data protection regulations.

In a next step, it was decided that the accident declaration form should be reviewed and adapted where necessary. This work will be carried out by the data protection experts in the near future.