ETSI EN 303 645 Data Protection Provisions

Start with the actual provision set. Clause 5.8 addresses confidentiality for personal data moving between the device and services, stronger treatment for sensitive personal data exchanged with associated services, and accessible documentation of external sensing capabilities such as optical or acoustic sensors.

Clause 5.10 applies when telemetry is collected and expects that telemetry, including log data, is examined for security anomalies. Clause 5.11 addresses user-data erasure from the device, personal-data removal from associated services, clear deletion instructions, and confirmation after deletion. Clause 6 adds consumer-facing information, consent, withdrawal, telemetry minimisation, and telemetry transparency requirements.

For clause 5.8, do not stop at a generic statement that traffic is encrypted. The useful evidence is a route-by-route map that shows which personal-data category uses which secure communication mechanism, what security guarantees it provides, and which cryptographic details are implemented.

TS 103 701 assesses whether secure communication mechanisms referenced by personal-data entries provide confidentiality for the relevant use case, whether the mechanism is appropriate for the technology, operating environment, risk, and usage, and whether the implemented cryptographic settings match the IXIT documentation.

Telemetry has two separate duties in the grounding. Clause 5.10 expects security-anomaly examination if telemetry is collected. Clause 6 expects transparency about what telemetry is collected, how it is used, by whom, and for what purposes, and says personal-data processing in telemetry should be kept to the minimum necessary for the intended functionality.

The practical evidence should distinguish telemetry used for security examination from telemetry collected for other product purposes. TS 103 701 uses IXIT 24-TelData for telemetry description, purpose, security examination, and linked personal-data categories, and IXIT 2-UserInfo for the consumer-facing telemetry documentation.

Clause 5.11 requires simple functionality for erasing user data from the device and recommends simple functionality for removing personal data from associated services. It also calls for clear instructions and clear confirmation after personal data has been deleted from services, devices, and applications.

The deletion review should cover more than a factory reset button. EN 303 645 notes that factory reset may be inappropriate in shared-use situations where one user needs to remove their own personal data without disrupting the owner or future users.

Use this checklist before publishing a claim, submitting evidence to an assessor, or using the page in procurement. Each item is grounded in the ETSI provisions or TS 103 701 evidence model and should be tied to a product version and assessment boundary.