Batteries are becoming more connected, making their data just as valuable as the materials they contain. From electric vehicles to portable electronics, battery systems now generate continuous streams of information on performance, usage, and condition.
This data is essential for safety, traceability, and circularity. At the same time, it raises an important question: what happens to this data when the battery reaches its end-of-life?
The concept of the “Right to be Forgotten”, rooted in data protection law, especially the General Data Protection Regulation (GDPR), introduces new considerations for battery lifecycle management. As Digital Battery Passports (DBPs) expand, balancing transparency with privacy becomes a critical challenge for industry and regulators.
Why Battery Data Raises Privacy Questions
Modern batteries are no longer passive components. Through battery management systems and connected platforms, they generate large volumes of data.
This can include performance metrics, charging patterns, usage history and location-linked operational data. In certain cases, especially in electric vehicles or shared mobility systems, this information can be linked to individuals or identifiable usage behaviour.
Under GDPR, any data that can be connected to an individual is considered personal data and must be handled accordingly.
This means that battery data is not only a technical asset but also a regulated data category.
Understanding the Right to Be Forgotten
The “Right to be Forgotten”, formally known as the “Right to Erasure” under GDPR, allows individuals to request that their personal data be deleted under certain conditions.
This right applies when data is no longer necessary, when consent is withdrawn or when data has been processed unlawfully.
In the context of batteries, this raises practical questions. If a battery has been used by a specific individual or fleet operator, and its usage data is stored in a Digital Battery Passport, can that data be erased when the battery reaches the end of its life?
The answer is not straightforward. It depends on how the data is structured and what type of information is stored.
The Tension Between Traceability And Data Erasure
The EU Battery Regulation requires that batteries maintain a consistent digital record throughout their lifecycle. This includes data needed for safety, performance monitoring, recycling and compliance verification.
This creates tension. On the one hand, regulators require long-term data availability to support traceability and circular-economy goals. On the other hand, GDPR requires that personal data should not be retained longer than necessary.
The European Commission highlights that data protection principles must be integrated into all digital systems, including emerging industrial data frameworks.
Balancing these two requirements is a key challenge in implementing the Digital Battery Passport.
What Data Should Be Retained And What Should Be Deleted
Not all battery data is personal. Much of the information stored in a DBP relates to materials, chemistry, performance and technical characteristics. This type of data can be retained without privacy concerns.
The challenge arises with usage-related data that may be linked to individuals.
A practical approach is to separate data into categories. Technical and compliance data should be retained to support recycling, safety and regulatory reporting. Personal or user-linked data should be anonymised or deleted when it is no longer required.
Anonymisation plays a critical role here. If data can no longer be linked to an individual, it may fall outside the scope of GDPR while still retaining its value for analysis and traceability.
End-Of-Life Data Handling In Practice
When a battery reaches the end of its life, several processes take place. It may be collected, dismantled, recycled or repurposed. At this stage, data handling should follow a structured approach.
First, any personal or user-linked data should be assessed. If it is no longer needed for operational or legal purposes, it should be removed or anonymised.
Second, core lifecycle data should be preserved. This includes information on composition, safety history and performance, which is essential for recycling and compliance.
Third, access controls should be updated. Different stakeholders, such as recyclers, may require access to specific data, while other information remains restricted.
This aligns with broader principles of data governance and lifecycle management in battery passports, where data is managed differently at each stage of the lifecycle.
Designing Privacy-By-Default Battery Passports
To address these challenges effectively, privacy considerations must be built into the system from the start. This is often referred to as “privacy by design” under GDPR.
In the context of Digital Battery Passports, this means minimising the collection of personal data, separating identity-related information from technical data and implementing strong access controls.
It also involves defining clear retention policies. Data should not be kept indefinitely if it is no longer required, especially when it relates to individuals.
By designing systems in this way, organisations can ensure compliance with both data protection laws and battery regulations.
How BASE Supports Privacy-Compliant Battery Data Management
At BASE, we recognise that data transparency must go hand in hand with data responsibility. Our Digital Battery Passport framework is designed to support secure, structured and privacy-aware data management across the battery lifecycle.
We focus on separating sensitive information from technical data, enabling controlled access and supporting anonymisation where required. This ensures that stakeholders can access the data they need for compliance and operations, while respecting data protection requirements.
Through our work, BASE contributes to developing Digital Battery Passport solutions that align with both regulatory frameworks and real-world operational needs.
Looking Ahead
As battery systems become more connected, the importance of responsible data management will continue to grow. The end-of-life stage is a critical point where privacy and traceability requirements intersect.
Digital Battery Passports provide a powerful tool for managing battery data, but their success depends on how well they integrate data protection principles.
Organisations that adopt privacy-aware approaches today, will be better positioned to meet regulatory expectations, build trust and support a transparent and sustainable battery ecosystem in the future.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References
GDPR Article 17 – Right to Erasure: https://gdpr.eu/article-17-right-to-be-forgotten/
EU Battery Regulation (Regulation EU 2023/1542): https://eur-lex.europa.eu/eli/reg/2023/1542/oj
European Commission – Data Protection Overview
https://commission.europa.eu/law/law-topic/data-protection_en
European Commission – Circular Economy Action Plan: https://environment.ec.europa.eu/strategy/circular-economy-action-plan_en