On 15 December 2010, the Belgian Data Protection Commission issued a recommendation in relation to mobile mapping (defined by the Data Protection Commission as "recording pictures of the road network through vehicles equipped with digital cameras").
Data protection laws will apply to mobile mapping as it may process recognisable vehicles, houses, individuals and potentially even sensitive data (e.g. a patient entering a medical practice).
The recommendation requires that data subjects be informed about their rights, the fact of the data processing and its purposes, as well as the identity of the data controller and the recipients of the data. The Data Protection Commission suggests a set of measures aimed at ensuring this information obligation is respected.
The Data Protection Commission urges data controllers involved in mobile mapping to define the purpose of their processing very strictly and to stay in line with the prescribed purposes using appropriate technical measures. In this respect, the Data Protection Commission favours technologies designed to take data protection rights immediately into account (e.g. "blurring"), rather than applying corrective measures after recording the pictures.
The Data Protection Commission remains at the disposal of the mobile mapping technology sector to discuss this matter and examine which technical measures can ensure compliance with data protection obligations on a case-by-case basis.