Dogtrousers
Kilometre nibbler
Not necessarily behind the wheel. Not necessarily even in the car.If the data is just e.g time-series controller inputs and GPS location, I'd argue that's not personally identifiable unless accompanied by evidence that puts a named driver behind the wheel at that time. .
For instance if the data has a location and a phone number then the phone number can be treated as an identifier of a person, and the location is information about that person. It's "where the person was" (whether or not they were driving). Under those circs I'd say this is probably Personally Identifiable Information.
You could argue that if the data has a location and an account id, and the account id identifies a person then the data is info about that person, whether they were there or not. It's "the location of the account holder's car".
And the manufacturer could say, I need to process this data in order to provide a service to fulfil a contract (to make the car work).
Now if you wanted to use the info for prosecution of someone, that's a different kettle of fish: I put it to you, Mr X that you were driving the vehicle at place Y at time Z, then yes you'd probably need additional evidence. But just for it to be classed as PII (or not) that's something that lawyers like to blather over for ages.
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