Under the influence of massive data collection both by commercial parties and by public authorities the protection of personal data is getting more and more under pressure. The data protection authorities justly take a strong stand against abuse of personal data. However in the case of C-ITS it seems to lead to restrictive interpretations of the data protection legislation. Such interpretations may have an inhibitory effect on innovation. In this stage of development industry would benefit from legal certainty. In this paper we will argue that Cooperative Intelligent Transport Systems (C-ITS) using the 802.11p. wifi protocol do not necessarily process personal data. The arguments are based on the
legislation, opinions of the EU Data Protection Authorities and recent jurisprudence of the EU Court of Law. Now the implementation phase of C-ITS is approaching and the technical specifications are to a large extend developed this seems a good moment to bring our opinion forward.
