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🌐 Support Explanation: Why Travel Itineraries Are Classified as GDPR Personal Data?

This page explains why location-based travel records are included in this category and why their retention must be managed carefully.

 

Thank you for seeking clarification on why travel information, such as itineraries and flight details, is flagged by our system as data requiring GDPR compliance. Many clients initially assume that only overtly sensitive data (like health or financial records) falls under GDPR. However, under the regulation, any information that can directly or indirectly identify a person is considered personal data.

1. The GDPR Definition of Personal Data

The General Data Protection Regulation (GDPR), in Article 4(1), defines personal data as:

"any information relating to an identified or identifiable natural person ('data subject')."

This includes identifiers such as a name, an identification number, location data, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

2. Why Travel Information Fits the Definition

Travel itineraries and flight details are classified as personal data because they contain location data related to a specific time and individual:

  • Location Tracking: A flight ticket or an itinerary explicitly documents where a named individual was (departure airport) and where they were going (arrival airport) on specific dates and times.

  • Identifiability: This granular information about a person's movements and schedule allows for their identification, location, or the creation of a profile based on their travel history.

Even though it is not "sensitive data" (which includes health, political opinions, or religion), it is still classified as personal data that must be protected.

3. Legal Precedent: The Danish Case Example

This classification is supported by legal precedent established in the European Union.

📰 Case Example: Shortly after GDPR implementation, the Danish Data Protection Agency (Datatilsynet) successfully pursued a case against a taxi company. The company was found to be in violation because they had stored customer taxi booking data (which tracks a person's journey from Point A to Point B at a specific time) for too long without a legitimate purpose.

  • Source: Datatilsynet indstiller taxaselskab til bøde på 1.2 mio. kr. (A specific reference to this case can be found on the Datatilsynet website, March 2019).

This ruling confirmed that location and movement records, like those found in itineraries, are subject to strict GDPR retention rules.

4. Our Compliance Requirement

You stated that our system was expected to only catch sensitive and confidential data. While it certainly handles that, its core function is to ensure compliance with the GDPR's Storage Limitation Principle (Article 5(1)(e)):

Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

Therefore, we flag travel itineraries because:

  1. They are Personal Data (location/movement tracking).

  2. Once the trip is completed, the original processing purpose (e.g., booking, invoicing) is typically concluded.

  3. Without a new, documented, and legitimate purpose for retention (e.g., a specific legal requirement for tax audits), this data must be securely deleted.

Our system helps you meet this obligation by identifying these records when their retention purpose has expired.