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European Commission
Directorate General Information Society and Media, Network and Communication Technologies
BU29 BE 1049 Brussels Belgium
Mr. João da Silva, Director
Mr Gérald Santucci, Head of Unit, ICT for Enterprise Networking
Mr. Florent Frederix
Mrs. Viviane Reding


Introduction

The FoeBuD e.V. from Bielefeld has made it its aim to accompany and assist mankind on its way towards a communication society. FoeBuD’s know-how is meant to serve the goal that technology be sensibly and safely used for the co-existence of people. The FoeBuD has no particularistic interest in the issue. Critical questioning of the technology and the ways of its presentation towards the public has made FoeBuD renowned the world over. We would like to submit our thoughts regarding the current consultations on RFID to the EU Commission.

The FoeBuD does not consist of lawyers and is not a data protection association. Therefore a number of our comments will not refer to data protection issues alone but also shed a light on other aspects. This is important to note, since a number of outcomes of the technology (also in terms of data protection issues) can almost only be understood under the light of interdisciplinary knowledge. RFID also touches the interests of human rights protagonists, committed citizens, environmental protectionists, and workers’ representatives.

The FoeBuD operates the web site StopRFID.de. We did not decide to use a stop sign as symbol for our campaign at random. StopRFID does mean the same as a stop sign does on the street: Come to a standstill, take a short rest, look to the left and to the right with concentrated attention, and drive on not until the journey can be continued in a really riskless way. We do not want the abolition of RFID but a law that protects the privacy of the citizens.

We regard it as imperative that legal adjustments be made with respect to RFID. This is of advantage also for the respectable industrial and trade corporations since it provides protection against (possibly irresponsible) competitors as well as their own share-holders, who could force the management to break principles of ethical handling of data as efficiently as at all possible. Therefore attached please find:

• Answers and Additions from FoeBuD e.V. to the workshop “RFID Security, Data Protection & Privacy, Health and Safety Issues” from May 16 and 17, 2006
• Response, criticism and suggestions for improvement by FoeBuD e.V. to the CDT “Privacy Best Practices for Deployment of RFID Technology” from May 1, 2006
• Comments by FoeBuD e.V. on the WP 105 “Data protection issues related to RFID technology” from November 18, 2005
• “Will Trade Civil Rights For Lentil Pottage: The ‘Tell Us All About You’ Knowledge Society” by Rena Tangens