Getting Consent From Drivers on the Go: A Privacy Consent Collection Framework for In-vehicle Systems

1. Challenge HERE Technologies, a digital location technology company that provides location-based services to various verticals, including Automotive, has been considering different means of acquiring consent in an in-vehicle context. Dependent on the use case, regulations such as General Data Protection Regulation (GDPR) may require HERE to obtain consent from drivers before collecting their data for navigation services. However, HERE does not have a direct relationship with drivers. HERE’s clients are vehicle manufacturers, and HERE provides their navigation service through SDKs to different vehicle manufacturers. Vehicle manufacturers design their own in-vehicle navigation systems based on the SDKs. HERE’s privacy notices need to be made available on the in-vehicle navigation system, to ensure drivers are informed about the collection and use of their data. Drivers are usually not fully be aware of parties that provision in-vehicle services, including navigation services, especially in connected vehicles. Therefore, it is challenging to ensure appropriate transparency with the data subject (drivers and/or other individuals) and to acquire consent from them, where necessary. Nonetheless, it becomes important to have an effective interface to communicate with drivers and obtain consent, where legally required.