Cap 3105 new CAA document has dropped

The CAA has just dropped this. This affects everyone and has good news as well as bad especially this remote ID stuff. Read it yourself and make your home conclusions. Here is the Document. Apparently there is more clarification coming for hobby frying clubs so I’m guessing Simon will have some updates soon.:+1: https://www.caa.co.uk/publication/download/25025?fbclid=IwY2xjawKKAv5leHRuA2FlbQIxMQABHnTbmfYFbTWIXlCmyvd1_Lqmk9-vMiWsSbXedP7aStUC8I2tarNjVh4JkzjT_aem_cF2SluYSRwjL7X8rGa_LuA

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I have added a post and I am sending this letter to the information commissioner, please feel free to copy and send yourself.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

[Your Address]
[City, Postcode]
[Email Address]
[Telephone Number]
[Date]

Subject: Concerns Regarding Privacy Implications of CAA’s Remote ID Proposals for UAS Operations

Dear Information Commissioner,

I am writing to formally express my concerns regarding the Civil Aviation Authority’s (CAA) recent proposal outlined in CAP 3105, specifically the proposed mandate for Remote ID broadcasting for Unmanned Aircraft Systems (UAS), commonly known as drones.

The proposed regulations, as detailed in CAP 3105 (Chapter 5), aim to require drones to transmit real-time identification and location information, explicitly including the precise location of the pilot. This proposal raises significant data protection and privacy concerns, notably under obligations established by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

In particular, I would like to draw your attention to several specific areas of concern:

  1. Transparency and Fairness (Article 5(1)(a) UK GDPR):
    The requirement to broadcast pilot location data without clear transparency measures and robust consent mechanisms may result in the unfair processing of personal data. Pilots must have explicit clarity regarding who can access their personal location data and how it will be used.

  2. Purpose Limitation (Article 5(1)(b) UK GDPR):
    While the stated aim of Remote ID is to enhance security and safety, unrestricted or inadequately controlled public access could lead to uses beyond these legitimate purposes, thus violating the principle of purpose limitation.

  3. Data Minimisation (Article 5(1)(c) UK GDPR):
    The transmission of precise pilot location data in real-time appears excessive relative to the stated aims of safety and security. Less intrusive measures should be thoroughly considered before implementing a measure of this scope.

  4. Integrity and Confidentiality (Security) (Article 5(1)(f) UK GDPR):
    The proposal risks the potential misuse of pilot location data, exposing pilots to unnecessary risks including theft, harassment, or unauthorised surveillance, significantly compromising the principle of data security.

  5. Accountability (Article 5(2) UK GDPR):
    The CAA must demonstrate robust compliance with data protection requirements through comprehensive Data Protection Impact Assessments (DPIAs). Currently, the proposal lacks detailed evidence of such assessments and considerations of privacy impacts.

Given these substantial concerns, I respectfully request that the Information Commissioner’s Office engages proactively with the CAA to:

  • Clearly articulate the necessary limitations and controls regarding access to pilot location data.
  • Ensure that robust DPIAs are completed and published transparently to evaluate necessity, proportionality, and security measures associated with Remote ID.
  • Mandate comprehensive transparency and fairness measures, ensuring explicit consent and clear communication with drone pilots about how their data will be used, stored, and accessed.

I firmly believe it is crucial for the Information Commissioner’s Office to uphold and reinforce the rights of UAS pilots to privacy and data protection. I trust that your intervention will help ensure that any forthcoming legislation from the CAA fully respects and aligns with data protection laws established to safeguard the rights of UK citizens.

Thank you for your attention to this critical issue. I look forward to your response.

Yours sincerely,

[Your Name]

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Yes I have seen your post on Facebook I believe. Fait play for doing this but they are determined to do this remote ID stuff. Even there Reason for doing this is questionable to stay the least as Gatwick and drone incidents where used as a reason. It was later revealed that these drone incidents included drones being stolen and complaints made against drone operators that were flying legally. So not drones doing wrong. Even the Gatwick drone incident has a lot of questions left unanswered. We don’t have a working device as far as I know and we don’t have 100% coverage across the UK for internet. If the height is using GPS then we also know this doesn’t work properly yet. So yes more questions that anything at the moment. The sad part is we filled out the consultation and it was a big NO but they have completely ignored us. :+1: