Transportation smart cards to become anonymous?

The Israeli Law, Information and Technology Authority (ILITA) recently published draft guidelines regarding Data Protection and Privacy in smart cards in the public transport sector. The draft refers to personal cards, such as the rechargeable "Rav-Kav" (Hebrew for "Multi-Line") cards which are used on the bus and train systems. According to an agreement with the Ministry of Transport (MOT), the operators of such smart cards are required to retain numerous details, including card holders photo, I.D. number, private and family name, birth date, address, telephone numbers, email address, company and employee number. According to ILITA, in addition to the above information, the operators further collect details such as the card holder's gender, academic institution (if applicable) and card usage - for example: transport type (bus/train) and line number.

ILITA found that the information required for the Ministry of Transport to establish the correct public policy is non personally identifiable. Nevertheless, the ILITA refrained from determining in the draft, that concealing of personally identifiable information is required. The draft does state however, that the identifiable information may be used solely for the services provided by the operators according to their agreement with MOT and that if they wish to use it for marketing and sales, they are required to receive the holder's consent. The smart cards operators are not allowed to condition the purchase of a card on such consent.

In a first time directive of the sort in Israel, ILITA further determined that upon issuance of the card, the operators are required to offer the customers an option to purchase an anonymous card so long as the customer does not request a discount which requires the use of personally identifiable information. The offering of the alternative anonymous card is crucial in order for the customer's purchase to be considered of sound mind: "...the option of an alternative anonymous card must appear prominently on the signposts by the purchase stations, the operators' website and as part of the service providers service at the sales points", ILITA determined. The draft guidelines are published for public's comments on ILITA's website (Hebrew PDF).