Pay-As-You-Drive™ for Individual Vehicles
Sunday, 16 July 2006

Through the course of the plenary meetings on July 6, 2006, the CNIL debated the e-bonus project that ACT Concepts presented as a PAYD solution for individuals. The advantage of this solution with respect to individual privacy rights is that the data is used only to generate statistics and no raw data is stored or transmitted elsewhere.

Since November 2005 when the CNIL announced its position on global positioning systems as applied to individuals, ACT Concepts has proposed an innovative approach adapted to the following regulations :

The Responsibilities of the Insurer

  • The nature of the transmitted data

All use of personal data must be declared to the CNIL ; if the data has a clearly personal nature (birthdates, address...), it requires a Declaration. If, on the other hand, the data is deemed "sensitive", it then becomes necessary to have an Authorization that only government services can obtain (the police, the courts). The PAYD plan previously presented to the CNIL was rejected from the start because it kept a log of "sensitive" data including speed, position, and specific dates.

With the new e-bonus solution, the only information that’s stored and sent outside the electronic unit are the statistical findings. As a result, it becomes impossible to recreate an itinerary or to know a vehicle’s precise speed at a given location...even impossible to fine a driver!

  • The appropriateness of the transmitted data

As far as the declaration is concerned, the means must not lose sight of the objective. « The ends do not justify the means. » This is what the CNIL calls « appropriateness ». For example, tracking the different places where an insured driver parks his vehicle outside his residence would be excessive because it falls into the realm of daily personal habits, not driving habits.

The e-bonus system was intentionally designed not to store or transmit precise global positioning data to a third-party, whoever they may be. The system computes statistical distributions in real time but retains absolutely no trace of raw information. From the moment we decided to keep only the statistical distributions, we definitively renounced keeping detailed, precise records. E-bonus provides the indicators for measuring tendencies, not the exact information. This method proves to be sufficient and quite appropriate for evaluating driving behavior—and nothing more.

The Rights of the Insured

  • Opposition to using the data

Concerning the right of the insured to oppose the use of this driving data, the CNIL saw to it that the e-bonus device was designed to let the user activate and deactivate the function for evaluating driving conduct at his convenience.

  • Rights to Information : access and modification

To conclude, in his letter from July 13, 2006, Alex Türk, president of the CNIL, insists on the insured person’s rights to access and modify information : "(...) Finally, the commission will take care that persons whose vehicles are equipped with the e-bonus system have a complete understanding of the purpose of the device, the rights they hold under the law, and exactly what they are consenting to (...)".


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