Bolt: inquiry about identification documents

Saatja: Elīna Andrijevska <[email protected]>

Saadetud: 29.01.2024 11:52 Adressaat: SiM info <[email protected]>

Teema: Bolt: inquiry about identification documents

TÄHELEPANU! Tegemist on vä l jastpoolt asutust saabunud kirjaga. Tundmatu saatja korral palume linke ja faile

mitte avada!

Dear Sir/Madam,

We are reaching out to seek your guidance regarding the matter outlined below.

In light of the Digital Service Act (the DSA), Bolt, as a platform operator, is required to conduct a thorough identification of drivers registering on the Bolt platform.

In light of the above, we are seeking confirmation on whether we can utilize a driver's license

as an identification document in Estonia to fulfill the necessary driver identification under the DSA. Additionally, can we rely on a driver's license issued by other EU member states and countries outside of the EU?

From an operational standpoint, relying on driver's licenses would be more efficient and

would limit data processing under the GDPR, as we would not collect IDs and/or passport copies in addition to a driver's license.

We have taken note that a driver's license is not explicitly listed in clause 2(2) of the Identity Documents Act. However, driver's licenses do satisfy the criteria outlined in clause 4(1) of the

Act, which states that: "An Estonian citizen or an alien may also prove his or her identity with a valid document not specified in this Act if the name, photograph or facial image, signature or

image of signature and date of birth or personal identification code of the holder are entered therein".

Thus, our presumption is that we should be permitted to rely on a driver's license as an identity document in Estonia.

We eagerly await your response.

Best regards, Elina

Elina Andrijevska

Legal Counsel | Baltics

(+371) 24859963

[email protected]

blog.bolt.eu