Page 17 - Dittmar Quarterly Q1 2019

When speaking about MaaS and passenger rights, it is essential to have a good grip on especially consumer protection legislation and various laws regarding different forms of transportation. They all include several provisions on passenger rights. However, the legislation has not been prepared from the perspective of MaaS and, therefore, there are several shortcomings with respect to travel chains.
To guarantee the rights of passengers and a successful travel chain, it is therefore essential for the parties of a travel chain to be aware of their role within the travel chain and agree on which practical arrangements will allow information to be exchanged between stakeholders and finally delivered to the passenger during the entire life cycle of the travel chain. When you have done your homework with the legal issues, it is easier to enter the new market as reliable and potential player.
As usual, in a B2B context the mutual liabilities of the parties acting in a MaaS travel chain may be agreed on rather freely. However, the abovementioned passenger rights should be borne in mind as the legal position of a passenger may not be undermined. Hence, the parties may not mutually agree on such limitations to their liability that would ignore or waive the passenger rights set out in legislation.
Protecting passenger privacy
Securing the privacy of users is essential in a context where passenger and travel data is shared between different stakeholders. In addition to passenger rights and liabilities, a MaaS stakeholder must therefore have a thorough understanding of privacy issues.
As personal data is regularly processed, shared and refined within the travel chains, stakeholders must comply with data protection regulations. The definition of personal data is surprisingly extensive, and most of the data processed within the travel chains is considered to be personal data. This should be recognised already in the planning phase of the business. It is essential for the stakeholders to understand their role either as data controllers or data processors, because these roles involve various liabilities and obligations which may differ from each other.
Jukka Lång, Partner, Marketing & Consumers @JukkaLang
Kaisa Päivinen, Associate Suvi Syvänen, Associate
-120 Years of Thinking Ahead-
The openness of interfaces and interoperability of transport systems are essential factors in forming the future of mobility. Enhancing digitalisation and encouraging different modes of transport to work together seamlessly will hopefully not only facilitate the achievement of climate goals, but also offer new and intriguing business opportunities for both traditional and new players in the transport sector.