# The Interface of Privacy and Data Security in Automated City Shuttles: The GDPR Analysis
## 5 Conclusions and Future Work  
Many ACS manufacturers envisage the deployment of ACS for public transport in the coming years. According to The Global Market Insights report [63], its value will rise from USD 1 billion in 2021 to USD 4 billion in 2028. Addressing the privacy concerns is crucial and a major challenge for the adoption of the ACS. The GDPR EU law provides an unprecedented level of data protection. Nevertheless, the collection and further processing of personal data raise crucial privacy concerns. We have identified the challenges for the principles of purpose limitation and data minimization resulting from the immense amount of data processed by the ACS. These principles, encapsulated within the concepts of PbD and PbDf, aim to mitigate any risks to the fundamental rights and freedoms of data subjects by the implementation of appropriate technical and organizational measures. These risks are also associated with the multiple data controllers and data processors, and their roles in the lifecycle of data processing as stakeholders of ACS ecosystems. The multiplicity of stakeholders who are involved in collection, transfer, and storage of data complicates the transparency of processing, the adoption of the appropriate and sufficient security measures, and, finally, their compliance on the basis of the accountability principle. With regard to the responsibility of the data processors and sub-processors, new regulatory efforts have been initiated at the European level [64] with a view to reinforce the responsibilities throughout the supply chain. Similar efforts could be initiated for the management of the automated and connected vehicles supply chain. It should be highlighted that the efforts to address the regulatory complexity of the innovative ecosystems should be approached in an interdisciplinary way by examining all the existing regulatory aspects in the domains of AI, privacy, and human rights, together with the involving technologies per sector. For instance, in 2021, the draft of the AI act was circulated by the EU [65], destined to impact the critical infrastructures, the transport sector being one of them. In this work, we raise the complexity of the stakeholders' duties and how they may accumulate multiple roles and obligations. Our recommendation to the stakeholders, who act as controllers and processors, is to encompass all those factors to protect fundamental rights and prevent potential data breaches within the ACS environment. We advise to push for deploying specific use cases with constant security control, monitoring, and assessment overtime. Additionally, the present paper discusses the discrepancy between the privacy-preserving techniques and the way the same techniques are advocated by the GDPR. As the existing data protection laws leave much uncertainty about the effectiveness of pseudonymization and anonymization as major countermeasures, the present work recommends a combination of legal provisions, more fine-grained definitions and a description of specific technologies preventing from re-identifying personal data within the automated driving ecosystem. Additionally, we endorse continuous control and aggregated countermeasures to exchange data and knowledge leading towards lawful processing, secure interoperability, and safe integration of ACS to the new mobility concepts. As a matter of fact, the present findings can be considered as the foundation for a potential upgrade of the European personal data protection regulations to provide more granular insights on the ACS's stakeholders' roles and reconsider the de-anonymization risks for an optimal data privacy protection within the IoV environment. As an ongoing effort, and under the umbrella of the AVENUE project, a data privacy assessment will be implemented to rate, audit, and quantify the technical and organization mitigation techniques in place with regard to the GDPR requirements.