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Passenger Data & GDPR (RODO) — Minimum Necessary Details for Transfer Bookings
Every executive transfer booking involves personal data: names, phone numbers, travel itineraries. Under GDPR (known as RODO in Poland), both the company booking the transfer and the transport supplier are data processors. Send only what is necessary to execute the booking — more data does not improve service quality, it increases risk.
TL;DR
- Send only the minimum data required to execute the transfer
- Passenger name or initials + phone + flight number + route is sufficient
- Do not send: passport numbers, dates of birth, hotel room numbers, medical or sensitive details
- For VIP arrivals: use initials + company name on the sign, not full name
- Tell the passenger exactly what will be displayed on the meet & greet sign
Minimum required data — by purpose
| Data point | Purpose | Required |
|---|---|---|
| Passenger name or initials | Meet & greet sign | Yes |
| Contact phone number | Driver-to-passenger contact | Yes |
| WhatsApp availability | Contact method confirmation | Yes |
| Flight number | Flight monitoring | Yes (airport transfers) |
| Pick-up and drop-off address | Route | Yes |
| Number of passengers | Vehicle selection | Yes |
| Luggage description | Vehicle selection | Yes |
| Billing details | Invoice | Yes (if VAT invoice required) |
Not required — do not include in booking messages
- Passport or ID number
- Date of birth or PESEL
- Hotel room number
- Purpose of travel
- Medical or health information
- Access codes or unrelated personal details
Best practices for EAs sending booking requests
- Use initials on the meet & greet sign unless full name display is operationally necessary
- Use a shared EA or booking inbox — not the passenger's personal email — for confirmations
- Do not forward full passenger itineraries to the driver; the driver needs pick-up address, time, and passenger contact number only
- Do not include sensitive personal information in WhatsApp booking messages
What a GDPR-compliant supplier should confirm
Ask any new supplier the following in writing:
- Do you have a privacy policy covering ground transport bookings?
- Do you share passenger data with subcontractors, and if so, what data specifically?
- How long do you retain booking data?
- Can you confirm passenger data is used only for fulfilling the booking and not for any other purpose?
Copy-paste privacy note
Add this to booking messages when using a new supplier:
We provide only the minimum data necessary for service execution. Please use passenger details solely for this booking and share with the driver only what is required for pick-up.
Related resources
- Licensed vs Unlicensed Transfers in Poland: /knowledge/licensed-vs-unlicensed-transfers-poland/
- Invoicing & Payments — VAT and billing rules: /knowledge/invoicing-payments-vat-corporate-billing/
- Executive Assistant Transfer Checklist: /knowledge/executive-assistant-transfer-checklist/
Red flags
- Supplier asks for passport or ID numbers without explanation
- Booking confirmation forwarded to unknown third parties
- No privacy policy available on request
- Driver contacts passenger outside the booking window using retained number
License No 92/2019
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ul. Jana Zamoyskiego 81
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