The GDPR and collaborative driving: Riding on the edge of lawfulness?

This article focuses on a system that allows to warn the driver of a car for dangerous driving situations. This system relies on V2V comunication: each vehicle communicates data concerning its position, heading and speed to surrounding vehicles and does so, with a high frequency. Sharing of precise location data with a high frequency raises data protection questions. Although technical measures are taken to shield off the identity of drivers, risks of identification remain substantial. Is it in light of these circumstances possible to process location data in a lawful way? This article examines whether the processing of location data can be brought under one of the processing grounds mentioned in art. 6 GDPR and in doing so, contributes to the discussion of whether the GDPR is fit for purpose in modern horizontal applications.