interesting view on observability and purpose from EU

1 Mar 2024

      We now have new requirements - observability and purpose - it seems that
the idea of a general purpose wallet has been effectively eliminated in the
EU and by those states that mandate their
own wallets for their own creds.

  Statement by the Commission on unobservability on the occasion of the
adoption of Regulation 2024/... + The Commission welcomes the agreement
reached, which in its view, confirms that this amending Regulation does not
allow for the processing of personal data contained in or arising from the
use of the European Digital Identity Wallet by the Wallet providers for
other purposes than delivering wallet services. The Commission also
welcomes the inclusion of the concept of *unobservability in Recital (11c)
of the draft amending Regulation, which should prevent wallet providers
from collecting and seeing the details of user’s day-to-day transactions.* The
Commission is of the view that this concept means that there should not be
correlation of data across different services for the purposes of user
tracking or tracing or for determining, analysing and predicting personal
behaviour, interests or habits. At the same time, the Commission
acknowledges that, in full compliance with Regulation (EU) 2016/679, the
providers of European Digital Identity Wallets may access certain
categories of personal data with the user’s explicit consent, such as in
order to ensure continuity in the provision of wallet services or to
protect users from disruptions in their provision.* That data should be
limited to what is necessary for each specific purpose.’   *

AM_Ple_LegStatOther (europa.eu)
https://www.europarl.europa.eu/doceo/document/A-9-2023-0038-AM-007-007_EN.pd...

Tom Jones

Salvatore D'Agostino

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