Berlin Group recommendations on telemetry and diagnostic data

The so-called “Berlin Group” – International Working Group on Data Protection in Technology (IWGDPT) – has adopted a working paper on telemetry data with the aim of supporting manufacturers in particular in the design of telemetry and diagnostic functions that comply with data protection regulations.

The working paper first provides a definition and differentiation of telemetry and diagnostic data.

  • Telemetry data is information that is continuously collected and transmitted by devices or applications.
  • Diagnostic data, on the other hand, is only collected and transmitted in the event of certain events – e.g. errors.

Different scenarios for the use of telemetry and diagnostic data and the associated risks in terms of privacy and data protection are described.

For example, it can be problematic if users are not sufficiently informed about data collection or if data protection principles such as purpose limitation and data minimisation are not observed. Users should always have the option of limiting the scope of data collection or objecting to data collection. The working paper contains application examples, describes data protection risks and makes recommendations.