EU_KCM_Legal advice on usage data collection for the Deutschlandticket

This includes, among other things, the creation of a detailed data protection concept that ensures the lawful processing of all data arising from the field tests. Furthermore, a legal opinion must be prepared that analyzes, evaluates, and documents the relevant legal framework (in connection with affected legal areas such as data protection, labor, funding, antitrust, or state aid law) and includes legally sound recommendations for action. The expert opinion must be completed by the end of September 2026. The technical design of the intended solutions will be continuously accompanied from a data protection perspective to ensure compliance with legal requirements (privacy by design). In addition to the data protection review, ongoing monitoring during and after the field test phase is necessary. Ensuring legally compliant implementation, especially data protection compliance, as well as the creation of the necessary documents and contracts for this, is a central prerequisite for the start of the field test phase and a potential nationwide rollout from 2028 onwards. Furthermore, the service includes support in shaping the necessary legal, especially contractual, foundations, particularly regarding the definition of responsibilities and data flows. Finally, continuous legal support will be ensured before, during, and after the technical implementation of GPS tracking with optional beacon integration, as well as during the accompanying monitoring, in order to resolve emerging legal issues promptly, soundly, and legally securely.