Digitalization is a topic everyone is talking about. The network of machines and everyday appliances and objects (e.g. clothes, household appliances, parking spots, furniture) which are able to digitally communicate with each other is rapidly growing, both in numbers as well as density and enables new, innovative business models. Among them are ideas like pay-per-use office furniture or clothes, bespoke drugs or therapies, autonomous cars and self-optimizing, learning industry machinery and robots. In many cases, the innovation is based on analysis and refinement of large collections of data (“Big Data”) which has been gathered by the respective company. Such databases often also encompass personal data, quite frequently without an actual need which would justify their storage. Under the new data protection regime, in particular the principle of data minimisation, this is allowed only under very specific circumstances. Further, suitable data protection measures have to be considered already in the conception phase (“Privacy by Design“). Every innovative business model considered when exploring the possibilities of the digitalization, industry 4.0 or similar, should therefore be critically analyzed regarding its compliance with data protection requirements.
