The Article 29 Data Protection Working Party on RFID has issued their Opinion 5/2010 in relation to the industry proposal for a Privacy Data Protection Impact Assessment Framework for RFID Applications. It's retrievable here.
Briefly, the Article 29 Data Protection Working Party does not endorse (technically: rejected) the proposed response from the industry mainly due to the absence of a CLEAR privacy and data protection approach in it's proposed framework. Besides, the Working Party opined that a rigorous consultation phases with stakeholders are of relevance - as to determine the viability - of the proposed framework. The industry proposal, in a way, failed to address the same. In particular, the issue of tag deactivation in the retail sector needs a much more coherent and clarity explanation. Overall, the proposal failed to address the concerns on transparency of RFID usage ("information and transparency on RFID use") and the emphasis on "security and privacy by design".
