The Compliance Highway – Navigating Global Regulations in Automotive Data Privacy
Your vehicle isn’t just connected, it’s collecting. Every trip generates data that falls under global privacy laws. GRC teams must manage consent, control data flows, and prove accountability.
The Data-Driven Car
Modern vehicles collect everything.
Driving habits. Voice commands. Location trails. Biometrics.
Your car is no longer a product; it’s a sensor network that reports constantly to manufacturers, insurers, and service providers.
Each data point creates new privacy obligations under laws like GDPR, CCPA, and China’s PIPL.
The New Compliance Terrain
Automotive data privacy isn’t theoretical—it’s regulated.
Here’s how the major frameworks apply:
GDPR (European Union): Vehicle data linked to a VIN or driver is personal data. Controllers must obtain explicit consent and ensure lawful processing.
(Cooley)CCPA / CPRA (California): Expands consumer rights to include connected-vehicle data like geolocation, infotainment history, and sensor metrics.
(Cooley)China’s PIPL: Restricts cross-border transfers and imposes strong obligations for driver and vehicle data processed in or sent from China.
Upcoming EU Legislation: Will grant third parties access to in-vehicle data for repair and service markets.
(Reuters)
Each jurisdiction expects automakers to treat data protection as a built-in feature, not an afterthought.
Where GRC Teams Struggle
Unclear data ownership between automaker, driver, dealer, and insurer.
In-vehicle consent that fails to meet legal standards for clarity and control.
Data-sharing contracts missing Article 28 GDPR processor terms.
Vendor exposure from telematics or infotainment providers with weak controls.
Cross-border transfers lacking documented legal basis or transfer impact assessments.
Every one of these weak points can become a regulatory headline.
Your GRC Roadmap for Privacy
Map Data Flows
Identify what personal data is collected, who processes it, and where it travels.Run DPIAs
Conduct Data Protection Impact Assessments for new in-vehicle systems and OTA updates.Design for Consent
Create in-vehicle privacy notices and clear opt-in/opt-out mechanisms.Contract for Control
Include data processing terms, audit rights, and breach-notification clauses in supplier contracts.Certify Your Program
Overlay ISO/IEC 27701 with your ISO 27001 system to establish a Privacy Information Management System.Train for Transparency
Make privacy-by-design part of your engineering culture, not just compliance paperwork.
Case Example
A U.S. automaker shares telematics data with an insurance company for usage-based coverage.
A DPIA reveals a re-identification risk: data can be traced back to the driver.
The GRC team enforces anonymization, updates the consent interface, and revises the insurance partner contract with strict retention limits and deletion clauses.
The outcome? The automaker maintains compliance under both CCPA and GDPR—and preserves trust with customers.
Key Takeaways
Privacy risk is operational risk.
Cars now generate personal data across borders.
GRC leaders must manage consent, contracts, and continuous oversight.
ISO/IEC 27701 gives structure, but culture ensures success.
References
European Data Protection Board Guidelines on Connected Vehicles
ISO/IEC 27701:2019 Privacy Information Management
California Privacy Rights Act (CPRA)
Stay Connected
Subscribe to The GRC Compass for practical insights on data governance, privacy, and compliance in mobility.
Follow MY GRC POV Podcast for real-world discussions on privacy frameworks and risk management at www.mygrcpov.com/follow.
Share this article with your compliance or engineering teams to build stronger privacy practices across your fleet.
Disclaimer
This publication is for informational purposes only and does not constitute legal advice. Readers should consult legal counsel or privacy professionals before implementing data protection controls in their organization.
#GRC #RiskManagement #Compliance #DataPrivacy #GDPR #CIPM #PrivacyByDesign #ConsumerProtection