20 December 2019
"This assessment concludes, inter alia, that the Commission package expands the scope of the European Criminal Record Information System for Third-Country Nationals (ECRIS-TCN) beyond the purposes stated in the ECRIS-TCN Regulation. This expansion constitutes a serious interference with the rights to respect for private life and to protection of personal data."
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European Parliament Study: The European Commission package of ETIAS consequential amendments - Substitute impact assessment (pdf):
"The necessity of this interference is called into question due to the potential overlap between the Schengen Information System (SIS) and ECRIS-TCN. The assessment moreover finds that the provisions on the automated processing of ETIAS application files also entail interference with the rights to respect for private life and protection of personal data.
It also highlights the existence of data quality issues and calls into question the relevance of certain data stored in EU information systems. That said, it finds the provisions on access by the ETIAS Central Unit and the ETIAS National Units relatively well balanced and recommends certain clarifications."
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