Yoti Ltd
Yoti
Yoti has developed a suite of digital identity products and continues RD activities.
ID: 629975839315-28
Lobbying Activity
Response to Digitalisation of travel documents and facilitation of travel
9 Dec 2024
We welcome the Commissions DTC initiative. Digitising travel documents could improve border processing and security, and reduce burdens for travellers and administrations. In line with our feedback to previous consultations, we would highlight that privacy, security and inclusivity will be key drivers of public trust and adoption. Ensuring the right level of privacy and data protection In prior consultations, we have emphasised the importance of privacy and potential issues with travel data storage. DTC technology will need to come with robust safeguards. Although DTCs exclude fingerprints, the temporary storage of facial data will remain sensitive. We recommend data minimisation, strong encryption, and secure deletion protocols that are aligned with GDPR standards. There should be clear guidelines on user data control. Previous feedback indicated concern about centralised databases. The EU DTC system should ensure transparency in how travellers data will be used. It should also offer them easy to understand rights to opt-out, review or revoke data sharing, as is currently possible within the Yoti app. Privacy notices should be written in clear and accessible language, and link to fuller policy documents. Choice, flexibility and inclusivity Recent consultations indicate that while many are likely to welcome the use of digital identity wallets and credentials to travel, a significant portion may still prefer to use physical documents for a variety of reasons. Therefore, offering both digital and physical documents, and parity between them, is essential. A voluntary approach to DTC adoption would align with EU inclusivity principles. It would also ensure that all residents can travel securely, including those who may need extra time to familiarise themselves with digital systems. We also acknowledge that previous feedback to this consultation suggests that reliance on technology that may not be uniformly accessible across all demographic groups or regions may be an obstacle. Therefore, ensuring that robust inclusivity measures are in place prior to launch would ensure public trust and facilitate smoother DTC adoption. Interoperability and cross-border cooperation To maximise effectiveness, we would suggest that DTCs should be interoperable across states, but also with international frameworks, and align with International Civil Aviation Organization standards. We understand that EU Member States may have different levels of readiness, but a unified approach will be paramount. We would suggest that EEA members, Switzerland and the United Kingdom should also be associated with this work. Given the high volume of cross-border movement and the potential benefits of streamlining border crossings between EU Member States and the aforementioned countries, there is significant potential to boost DTC utilisation. Recommendations and conclusions Our feedback aims to balance DTC goals with safeguards that uphold EU values of privacy, inclusivity, and security. Based on feedback from past consultations, we recommend: Users should be free to choose to use DTCs when crossing borders. There should be parity between digital and physical documentations to ensure that citizens can choose between physical and digital credentials. The system must ensure data use transparency and the highest possible levels of data protections. Clear notices, data storage limits and state of the start GDPR-compliant encryption will ensure user trust and uptake DTCs should be interoperable and usable across and between not just EU Member States. They should align with international and ICAO standards. Switzerland, the UK & EEA states should be associated with this work. DTCs have the potential to greatly enhance EU travel facilitation, but success depends on a balanced approach that respects user choice, data protection, and inclusivity. A measured rollout with periodic reviews will help the Commission achieve its objectives and address the valid
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