Ministerio de Transportes, Movilidad y Agenda Urbana – No Violation (Spain, 2021)
General GDPR enforcement action
This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.
The Spanish Ministry of Transport conducted a study on commuting trends using mobile phone data. The Spanish DPA found that the data was properly pseudonymized and not reusable for other purposes, ensuring privacy compliance. This case shows how data can be used responsibly for public studies.
What happened
The Spanish Ministry of Transport used pseudonymized mobile phone data to study commuting trends during the COVID pandemic.
Who was affected
Individuals whose mobile phone data was collected to analyze daily commuting patterns.
What the authority found
The Spanish DPA concluded that the Ministry's measures ensured the data could not be linked to individuals or reused for other purposes, complying with GDPR.
Why this matters
This decision highlights the importance of pseudonymization and data protection in public studies. It reassures businesses that with proper safeguards, data can be used for research without breaching privacy laws.
GDPR Articles Cited
The Spanish DPA investigated the impact study carried out by the Spanish Ministry of Transport on the daily commuting trends during the first days of COVID pandemic. In particular the investigation focused on whether the data used for the study was appropriately pseudonymised and whether there was any risk of re-using the data for different purposes to the original ones. Data from individuals' mobile phones belonging to one operator were collected during several days to measure daily commuting trends of people on regular days. This data was pseudonymised by the operator with hash techniques and by grouping the data by areas of origin of at least 5000 people. Then the data was provided to a consultant firm that aggregated such data automatically and then processed it to produce the indicators required by the Ministry of Transport. All the measures put in place to unlink the data, pseudonymise, aggregate and further group and process it to produce the final indicators are considered enough to make practically impossible the identification of the data subjects that originate it. Has the mobility study of the Spanish Ministry of Transport been conducted in compliance with GDPR in particular with the appropriate pseudonymisation of the data and the impossibility to re-use the data for incompatible purposes? The Spanish DPA held that the measures put in place by the Spanish Ministry of Transport to conduct the mobility study were enough to ensure that the data could not be associated to individual people or re-used for purposes incompatible with the original ones.
Outcome
No Violation
The DPA investigated and found no violation.
Related Enforcement Actions (0)
No other enforcement actions found for Ministerio de Transportes, Movilidad y Agenda Urbana in ES
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. Ministerio de Transportes, Movilidad y Agenda Urbana - Spain (2021). Retrieved from cookiefines.eu
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