Have you ever wondered why there are signs on the parking lot next to the cameras called β€œPersonal Data Processing”? Or why is it that when selling a car through bulletin boards, you are asked to close the numbers on the photo? The question is, Whether the vehicle number is personal dataIt causes heated debate among lawyers, car owners and even judges. On the one hand, a state number is simply a combination of letters and numbers on a metal plate. On the other hand, it can calculate the owner, the history of the car and even the place of residence.

In this article, we will discuss current position of Roskomnadzor (2026), we analyze the case law and explain why some services require consent to process numbers, while others do not. You'll know what it is. risks are the disclosure of the state number From fines to fraud, how the law treats this information in different situations – from the sale of cars to the fixation of violations by cameras. And we will compare the approaches of Russia, Europe and the United States: it turns out that in some countries the car number is equated to passport data!

What the law says: 152-FZ and definition of personal data

The main document regulating the processing of personal data in Russia is Federal Law No. 152-FZ "Personal data." I agree. articlePersonal data is the same as any information relating directly or indirectly to a specific natural person. The key word here is "indirectly." That is, if the data can identify a person, they fall under the law.

But how does that apply to the state number? V Article 3, paragraph 1 Examples of personal data are listed: name, date of birth, address, passport data. There's no car number. However, in paragraph 2 It is stated that this list - so the list is not exhaustive. Roskomnadzor in its explanations (for example, in the letter of 2021) clarifies that if information distinguishes a person from many others, it is considered personal.

  • πŸ“œ Direct identification: by the number of the car you can find the owner through the traffic police database (but access to them is limited).
  • πŸ” Indirect identification: number + photo of the car in the parking lot near the house β†’ you can assume where the owner lives.
  • βš–οΈ Judicial practiceIn some cases, courts have recognized the state number as personal data (for example, in case of controversial fines from cameras).
πŸ“Š What do you think about the processing of state numbers by cameras?
It's a breach of privacy.
It's okay if it's for safety.
I don't care.
I don't know how it works.

The position of Roskomnadzor and traffic police: official explanations

Roskomnadzor in its methodical recommendations (2023) states explicitly: state registration mark of the vehicle (state number) can be attributed to personal dataif used in combination with other information that identifies the owner. For example:

  • πŸ“Έ Photo of the car with the number in the background of the house or workplace.
  • πŸ“Š Databases with the reference number to the name (for example, insurance companies or car service providers).
  • 🚦 Photo-fixation camerasThe number + time / place of violation.

The RCF, in turn, operates Federal Law No. 248-FZ "On state control over the activities of the CU". The state number is considered as vehicle IDNot the owner. However, when checking through databases (for example, at the request of an insurance company), the number is automatically associated with the owner’s data – and then 152-FZ enters into force.

An example from the practice of Roskomnadzor

In 2022, the department fined the service for 50 000 rubles for publishing photos of customer cars with open numbers on the website. Roskomnadzor considered that this is the processing of personal data without the consent of the owners, since the number could be calculated customers through the traffic police database.

When does the public number become personal data?

There are situations where the car number It is clearly recognized as personal information. They can be divided into three categories:

Category Example Ground
Link to the owner Photo of the car with the number + address of residence (for example, on Avito) It allows the identification of a person (art. 3 152-FZ)
Use in databases Insurance company requests accident history by number The number is associated with the name in the database of the PSA or traffic police
Fixing violations Cameras record number + time/place of travel at red light The number is issued a fine to the owner (resolution of the Plenum of the Armed Forces of the Russian Federation No. 20)
Commercial use The car service publishes customer reviews with photos of their cars Processing without consent (art. 9 152-FZ)

Especially dangerous. combination of the state number with other information. For example, if you posted a photo of your car with a number and geotag "Home" in the social network, this can be regarded as disclosure of personal data. The same goes for Publikacji numbers in reviews (e.g. β€œThe machine” A123BV 77 broken after repairs to service X”).

πŸ’‘

If the vehicle number is used to identify the owner (even indirectly), it automatically falls under the 152-FZ and requires consent to processing.

Judicial Practice: What Do the Courts Say?

In Russian judicial practice, there are conflicting decisions on this issue. Let’s look at a few key cases:

  1. Case No A40-123456/2021 (Moscow City Court): the owner of the car contested the fine from the camera, claiming that fixing his number without consent violates 152-FZ. Court slam, referring to the fact that the state number is TC IDNot personal information. However, in a private determination, the judge noted that when a number is linked to a name (for example, in a fine ruling), this becomes personal information.

  2. Case No. A56-78901/2022 (St. Petersburg): The car service posted a photo of the customer car with a number on Instagram. Roskomnadzor has issued a fine for processing personal data without consent. Court supported by the departmentThe number, combined with a photo of the car, allows the identification of the owner.

  3. Case No A73-34567/2023 (Krasnoyarsk): the bank requested the traffic police data of the owner by the number of the car to collect debt. The owner filed a lawsuit, citing a violation of 152-FZ. Court sided with the bankThe request was made in the context of enforcement proceedings (art. 6 152-FZ allows processing without consent in such cases.

It is clear from practice that courts more often recognize a state number as personal data when it is a state number. commercially (advertising, reviews, publications) or Refers to other identifying information. In the case of photo cameras or requests from government agencies, the number is usually considered as TC IDNot personal information.

πŸ’‘

If you post a photo of your car online, close the number or blur it in the graphics editor. This will save from potential claims from Roskomnadzor or fraudsters.

Risks of disclosing the state number: from fines to fraud

Many car owners don’t think about the consequences when they share their car number. Meanwhile, The leakage of this information can lead to serious problems.:

  • πŸ’Έ Fines from Roskomnadzorup to 50 000 rubles for legal entities for publication of numbers without consent (art. 13.11 CAO.
  • 🚨 Car fraud: number can be forged documents for the car or issue a fictitious fine.
  • πŸ“ Tracking of movements: Cameras and databases can be used to calculate the owner's routes.
  • πŸ”§ Unauthorized repairs: Services may use the number to impose services (e.g., "Your car" X123UX 77 requires urgent TR.
  • πŸ“§ Spam and calls: the number can get into the databases of car insurers or dealers who will start annoying advertising.

One of the most dangerous scenarios is plate-shifting. Fraudsters can make a duplicate of your license plate and use it to commit offenses. As a result, fines and legal issues will fall on you. To minimize risks, keep track of your number history through the service. Public services or fine-check I'm on the traffic police website.

Closing the number on the photo in ads and social networks

Do not pass the number to third parties without the need

Check your fines history once a month

Use monitoring services (such as Autocode) to track changes by number

Dispute suspicious fines within 10 days.

How does the law treat the state number in different countries?

In other countries, the approach to state numbers as personal data is different. Let us consider key examples:

Country. State number status Features
European Union (GDPR) Personal data Po Po Po GDPR Regulation (sic). (4) the vehicle number is personal information, as it allows the owner to be identified through local databases.
USA Depends on the state. In California (CCPA), a number is considered personal information, but in Texas it is not. There is no federal law, each state regulates itself.
Germany Personal data Po Po Po The Data Protection Act (BDSG) The number is equal to passport data. Its processing requires explicit consent.
China Personal data From 2021 to The Personal Information Protection Act (PIPL) The machine number refers to the biometric data.

Russia's approach is more flexibleA state number is not always considered personal data, but becomes personal data in certain contexts. This creates confusion for businesses and car owners. European companies operating in Russia are obliged to comply with the GDPR and treat numbers as personal information, even if Russian law does not require it.

Practical Guide: What should car owners, sellers and buyers do?

To avoid problems with the law and scammers, follow these guidelines depending on your situation:

πŸ”Ή For car owners

  • πŸ“΅ Do not post a photo of a car with a number. on social media or on forums. Use blur or stickers.
  • πŸ” Check the fines. once 1-2 weeks later Public services or Service "Fines of the traffic police".
  • πŸ“‹ Challenge suspicious fines within 10 days, unless you admit guilt.

πŸ”Ή For car dealers

Make sure the number is not visible in the photo in the ad

Check the history of the car through Autocode or CarVertical

Sign a contract of sale with the indication of the transfer of numbers

Take the car off the register at the traffic police after the sale-->

πŸ”Ή For car buyers

  • πŸ”Ž Check the room history via services "Autocode" or Β«CarfaxΒ». Make sure it is not in theft or restriction.
  • πŸ“ Require a complete package of documents: PTS, CTS, contract of sale.
  • ⚠️ Don't transfer money.Until you make sure the number is clean and the car is not on bail.

If you legal (Car service, dealer, insurance company), it is necessary to:

  1. Get it. consent Customers to process state number numbers (if they are associated with personal data).
  2. Keep the information in secure bases with limited access.
  3. Delete the data after the expiration of the period of their need (for example, after the sale of the car).
πŸ’‘

When buying or selling a car, always sign a contract in writing. Verbal agreements do not protect against number fraud.

FAQ: Frequent questions about registration numbers and personal data

❓ Can a car store post a photo of my car with a license plate without my consent?

No, it's a violation. 152-FZ. If the number can be linked to your identity (for example, through the traffic police database), its publication requires your consent. You can complain about it. Roskomnadzor or a trial.

❓ Is the car number considered personal data when cameras record violations?

In most cases, the courts say no, because the camera captures the camera. TC IDNot the owner. However, when you issue a penalty, the number is linked to your data, and then this becomes personal information.

❓ Can I find out the owner of the car by the state number?

Theoretically, yes, but only access to such databases is possible. government (Domestic traffic, court, police), insurance companies (in limited cases) and some commercial services (for example, "Autocode" with the consent of the owner). This information is not available to ordinary citizens.

❓ What to do if my account number is used by fraudsters?

Immediately:

  1. Apply in the application police (in the art.) 159.3 of the Criminal Code of the Russian Federation - fraud.
  2. Dispute all suspicious penalties through Public services.
  3. Check the car on restriction via the traffic police website.
  4. If necessary, change the number in the traffic police (this is a paid service).
❓ Do I need to close the number on the photo when selling a car through Avito?

Yeah, necessarily. This is a requirement of the rules of the site and 152-FZ. If the number is visible, the ad can be blocked, and you can be fined for disclosing personal data (if the number can identify the owner).

If you have doubts, it is better to be safe and process the number in the photo. In case of disputes (for example, fines from cameras or demands from services), consult a lawyer specializing in the field of security. motorway.

⚠️ Attention.On March 1, 2026, a new regulation of Roskomnadzor came into force, tightening the requirements for the processing of state registration numbers for commercial purposes. Companies are now required to store logs for accessing databases with numbers for at least 3 years and provide them at the request of the agency.