after the accident. This enables them to clarify the
circumstances of the accident.
Personal reference
Every vehicle is marked with a distinct Vehicle Iden-
tification Number (VIN). This Vehicle Identification
Number can be traced to the current and previous
owner of the vehicle, for instance, through informa-
tion from the Federal Motor Transport Authority in
Germany. There are also other possibilities to trace
the owner or the driver from data collected from the
vehicle, for instance, using the license number.
The data relating to assist systems in the vehicle is
also recorded. Whether for instance the affected
systems were switched on or off at the correspond-
ing time, whether they were only partially available
or were inactive. There is also the possibility of
tracking whether these vehicle functions controlled,
accelerated or decelerated the vehicle during the ac-
cident. Depending on the equipment, these func-
tions are, e.g:
Therefore, data generated from or processed in con-
trol units could be of personal nature or could be
treated as personal data under certain conditions.
Based on what kind of vehicle data is available, it
may be possible to trace your driving behaviour,
your location or your driving route or your usage.
— Adaptive Cruise Control (ACC)
— Lane Assist (Lane Assist)
— Park steering assistant
— Emergency braking function (Front Assist)
Your rights with respect to data protection
Under normal driving conditions, data is not recor-
ded. There is no audio or video recording from the
vehicle interior or surroundings. Personal data such
as name, gender, age or place where the accident
occurred is not stored in the EDR. However, third
parties such as law enforcement authorities may use
certain resources to connect EDR content to other
data sources, and therefore deduce the identifica-
tion of some of the people involved in the accident
when investigating the causes of the accident.
As per the applicable data protection act, you have
specific rights vis-à-vis Volkswagen, when it comes
to processing of your personal data.
Under this, you are entitled to gratuitous and com-
prehensive right to information vis-à-vis Volkswagen
and third parties, e.g. Hired breakdown service or
workshops, online service providers, if these have
stored your personal data. In this case, you may re-
quest information about the purpose of saving your
personal data and the source of these data. Your
right to information also includes communication of
data to other bodies.
For reading the EDR-Data, special equipment is re-
quired and the ignition switched on.
Volkswagen will not read or otherwise process any
accident data from the EDR without the approval of
the vehicle owner or other person authorised for use
of the vehicle. Exceptions are specified in the con-
tractual arrangements, or these are subject to gen-
erally binding regulations.
More information on your statutory rights, e.g. your
right to delete or correct data, can be found in the
corresponding applicable data protection instruc-
tions on the webpage of Volkswagen, including con-
tact data and reference of the data protection offi-
cer.
Data, that are stored only locally in the vehicle, can
be exported with the help of expert support, for in-
stance in a specialist company, by paying a charge if
need be.
Personal data
Data memory and services
Applicable in countries in the EU, where General Da-
ta Protection Regulation of the European Union is
effective.
Statutory requirements for publishing data
As far as there are legal requirements, Volkswagen is
obligated, in principle, to give out stored data in
specific cases such as investigation of an offence
when requested by government bodies to the extent
required from Volkswagen.
Data processing in the vehicle
Your vehicle is equipped with electronic control
units. Control units process data that is received
from vehicle sensors for instance, that is generated
by these units or exchanged from other units. Some
of the control units are necessary for the secure
functioning of your vehicle, some support you while
driving (driver assistance system), and others facili-
tate comfort or Infotainment functions.
Government bodies, are also authorized to export
data from the vehicles on their own within the scope
of the applicable right in a particular case. For in-
stance, information may be exported from the air-
bag control unit in case of an accident, which could
be useful for the investigation.
Personal data
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