Lisbon, Aug. 3, 2026 (Lusa) - A Citizens for Cybersecurity (CpC) initiative has asked the National Data Protection Commission for clarification regarding the processing of personal data within the Volta system for the deposit and refund of packaging.
«In many cases, the deposit amount can be credited to loyalty cards or customer accounts with retail chains. In such situations, it is important to clarify to what extent operators can link returns to the consumer's identity and cross-reference this information with data on previous purchases,» noted CpC in its request for clarification.
As it noted, this cross-referencing could make it possible to ascertain where and when a particular item of packaging was purchased, where it was returned, and to assess consumption patterns, travel habits or usual routes.
The initiative noted that this information is «potentially valuable» for commercial and marketing purposes.
Consequently, members of the public are asking which categories of personal data are collected during the return process, who processes the data, whether it is possible to link a return to the consumer's purchase history, and whether it is possible to link a returned container to the time and place at which it was purchased.
Furthermore, they wish to know, amongst other things, whether the system operators or retail chains can determine the time between the purchase and return of the packaging, whether the processing of the data allows consumption habits to be inferred, whether there are limits on the use of this data, and whether it is passed on to beverage manufacturers, distributors or the system's managing bodies, and for what purpose.
The CpC concluded its request for clarification by stating that environmental objectives must coexist with «respect for the principles of data minimisation, purpose limitation, transparency and the protection of citizens' fundamental rights».
The Volta system allows the deposit (0.10 euros) to be refunded after purchasing eligible plastic, metal or aluminium packaging.
This amount can be converted into cash, a shopping voucher, a discount voucher, a loyalty card or donated to charities.
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