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USE OF PASSENGER LOCATION CARDS IN THE ERA OF THE COVID-19 PANDEMIC, AND THE PROCESSING OF PERSONAL DATA OF AIR PASSENGERS

Purpose. The aim of the article is to analyse the processing of personal data of air passengers during the SARS-CoV-2 pandemic in the context of doubts that have arisen in connection with the need for these passengers to provide their personal data as part of filling out the Passenger Location Card questionnaire.

Method. The research method used in this study is case study.

Findings. In the study, it was showed that firstly, the data of air passengers processed in relation to the application of the Passenger Location Card by the State Border Sanitary Inspectorate in Warsaw should be protected under the provisions of the General Regulation on the protection of personal data. Furthermore, their controller, i.e. the State Border Sanitary Inspectorate in Warsaw, did not fulfil its obligations in this regard. This, in effect, justifies the conclusion that the processing process not in accordance with the law on the protection of personal data.

Research and conclusions limitations. The analysis concerned only passengers of aircrafts arriving and/or departing from airports located on the territory of the Republic of Poland.

Practical implications. The analysis carried out in this study may provide a solution to the issues that have arisen in the public sector with regard to the processing of personal data collected from air passengers on the basis of the Passenger Location Card questionnaire and thus, the conclusions may prove useful for data controllers who should be aware of such problems, but also for air travellers as data subjects who should be protected by the General Data Protection Regulation and their rights in this regard.

Originality. This analysis, if only for the reason that it is an analysis of a problem that has come to light relatively recently (March 2020), has so far, only been the subject of consideration in press articles.

