On 25 April 2024, the CNIL gave its opinion on the text instituting a pass in the “security zones” where traffic will be restricted due to the organisation of the 2024 Olympic and Paralympic Games. It accepted the legitimacy of the system, but made a number of observations about the use of photographs and the length of time the data will be kept.
The pass system put in place for the 2024 Olympic and Paralympic Games
To ensure the security of the Paris Olympic and Paralympic Games, the Prefect of Police will be setting up a number of perimeters within which traffic restrictions may be imposed. Some of these perimeters will be affected by a pass system containing a QR code.
This system will apply to access to the following security zones:
- the “SILT” or “grey” protection perimeter, within which motorised and pedestrian traffic will be restricted and checks will be carried out (security patrols, visual inspection and baggage searches, etc.);
- the “red” perimeter, where only road traffic will be restricted.
The pass will be issued following registration on a digital platform, which will involve the collection of personal data. The pass will contain a QR code to facilitate checks at the entrances to the zones, where large crowds are expected.
This system is based on what has been done for previous major events (for example, the hosting of the G7 in France in 2019), but adapted to the specific features of the Olympic and Paralympic Games.
To check whether you are eligible and find out more about the practicalities of organising your event, visit the Games Pass website.
Framework for the system
The file created will be implemented on the basis of the Order of 2 May 2011 relating to “files of residents of security zones” created on the occasion of a major event.
This text defines the purposes of these files, the categories of data that may be recorded, their retention periods, the accessors and recipients of the data and the procedures for exercising the rights of individuals.
In order to implement the pass system for the Olympic and Paralympic Games, the Order of 2 May 2011 has been supplemented to include new categories of data.
The CNIL’s observations on these changes to the Order
The CNIL commented on this amendment to the Order of 2 May 2011 in its deliberation of 25 April 2024. It confirmed the legitimacy of data processing to provide security for exceptional events. However, it called for certain changes to be made and issued a series of recommendations.
New categories of data
The decree authorises the processing of the following new categories of data: photographs, proof of access, copies of identity documents (national identity card, driving licence, passport or residence permit) and copies of vehicle registration certificates.
Following the CNIL’s observations, copies of national identity cards, driving licences, passports and residence permits will only be kept for the time required to issue the access document. Other data will be kept for three months, as was previously the case.
In its opinion, the CNIL also considered that while the collection of photographs could be justified in view of the scale of the checks to be carried out during the Olympic and Paralympic Games, it should be limited to events of this scale. As a result, the published order stipulates that it is not compulsory to collect photographs.
Transmission of data to the event organiser:
Organisers of the Olympic and Paralympic Games must also issue a pass to allow people who are not spectators to access the event facility itself.
To this end, the decree allows the organisers of major events held in the security zone to receive certain data from the residents’ file.
This transmission will not concern spectators.
On this point, the CNIL specifies that :
- data should only be passed on to the organiser if the latter does not collect the same data itself;
- For people (coaches, referees, doctors, etc….) wishing to access the establishments and facilities hosting a major event, an administrative enquiry will be carried out before access is authorised. These specific enquiries do not apply to spectators or people simply wishing to access other venues or buildings in the area, in particular homes or businesses unrelated to the event.