Take-Aways (AI)
  • The Fede­ral Supre­me Court con­firms: Data avo­id­ance and data mini­mizati­on app­ly despi­te strong encryp­ti­on; unneces­sa­ry per­so­nal data must not be coll­ec­ted in the first place.
  • Data secu­ri­ty alo­ne does not justi­fy the trans­mis­si­on and sto­rage of super­fluous con­sump­ti­on data; “non-exi­stent data can­not be misused.”

Even with encryp­ti­on, which takes 640 tril­li­on years to cir­cum­vent, the prin­ci­ples of data avo­id­ance and data eco­no­my must be obser­ved. Thus, the Fede­ral Supre­me Court ruled in the 1C_273/2020 (inten­ded for offi­ci­al publi­ca­ti­on). In this decis­i­on, the court deals in detail with the admis­si­bi­li­ty of data pro­ce­s­sing by elec­tro­nic water meters and coins the for­mu­la: “non-exi­stent data can­not be misused”.

It is not often that the Fede­ral Supre­me Court speaks of tril­li­ons. In this ruling of Janu­ary 5, 2021, it did so in con­nec­tion with radio-based water meters. The bone of con­ten­ti­on was the decis­i­on in Auen­stein (AG) to con­vert from mecha­ni­cal to elec­tro­nic meters. The muni­ci­pa­li­ty hoped that this would increa­se effi­ci­en­cy in bil­ling. On the other hand, the com­plainant feared that unaut­ho­ri­zed third par­ties could pene­tra­te the radio system and crea­te a con­su­mer pro­fi­le. He also felt that the per­ma­nent trans­mis­si­on of data vio­la­ted his per­so­nal rights and dis­re­gard­ed the prin­ci­ple of data avo­id­ance. Accor­din­gly, he deman­ded that the mode of ope­ra­ti­on of the new device be reset to that of a con­ven­tio­nal meter, par­ti­cu­lar­ly as more data-saving vari­ants are available.

The muni­ci­pa­li­ty, on the other hand, argued that the­re was no inte­rest in the data and that its decryp­ti­on, accor­ding to the infor­ma­ti­on pro­vi­ded by the equip­ment manu­fac­tu­rer, would requi­re “a peri­od of 6.4E+20 or 640,000,000,000,000,000 years” (ruling WBE.2019.383 of the Aar­gau Admi­ni­stra­ti­ve Court of April 8, 2020, E. 4.2).

In a first step, the Fede­ral Supre­me Court clas­si­fi­ed the data on water con­sump­ti­on as per­so­nal data and their recor­ding and trans­mis­si­on as data pro­ce­s­sing (E. 5.3.2). It then affirm­ed an inter­fe­rence with infor­ma­tio­nal self-deter­mi­na­ti­on (Art. 13 para. 2 BV) and asses­sed its per­mis­si­bi­li­ty against the stan­dard of Art. 36 BV (E. 5.4). In prin­ci­ple, it affirm­ed both the legal basis as well as the public inte­rest and the pro­por­tio­na­li­ty – howe­ver, this only for the Invoi­cing date (E. 5.6). It found it inad­mis­si­ble that the water meter also stores the hour­ly values for eight months and trans­mits them by radio every 30 seconds. To this ext­ent, the Fede­ral Supre­me Court denied pro­por­tio­na­li­ty, becau­se the­re was no need for the Neces­si­ty missing

This is not affec­ted by the fact that, accor­ding to the pre­cise and con­vin­cing expl­ana­ti­ons pro­vi­ded by the lower court, this data is very well pro­tec­ted and misu­se can be vir­tual­ly ruled out or seems very unli­kely. […]. Data secu­ri­ty alo­ne does not out­weigh the fact that more per­so­nal data is being pro­ce­s­sed than neces­sa­ry. Other­wi­se, the prin­ci­ple of neces­si­ty would no lon­ger be rele­vant if the enti­ty pro­ce­s­sing the data can pro­ve that it has taken suf­fi­ci­ent pro­tec­ti­ve mea­su­res. Howe­ver, the prin­ci­ple of neces­si­ty or data avo­id­ance and data eco­no­my aims to ensu­re that data that is not neces­sa­ry is not coll­ec­ted and pro­ce­s­sed in the first place. In this sen­se, their pro­tec­tion is also bet­ter ensu­red: non-exi­stent data can­not be misu­s­ed. (E. 5.5.3 a.E.)

Against this back­ground, the asser­ti­on of the muni­ci­pa­li­ty that it did not want to use the sur­plus data (E. 5.4.1 a.E.) was also unhel­pful. The Fede­ral Supre­me Court par­ti­al­ly upheld the com­plaint and refer­red the mat­ter back to the muni­ci­pal coun­cil for a reassessment.