Data Security Law Blog

Trade Off Between Privacy and Convenience: Germany’s New Digital Mail Service

In a country renowned for protecting the privacy of its citizens, Germany has undertaken a pilot program that does just the opposite. In a trade off between privacy and convenience, German residents can now enroll in a digital service where their mail is emailed to them anywhere in the world.

Germany’s national postal service, Deutsche Post, is offering an e-scan service on a trial basis. With the customer’s consent, the German postal service opens the customer’s mail, scans it and then emails it to the customer. The pilot program is restricted to letters and postcards and costs 5 Euros or about $5.75 per month.

It’s ironic that in an EU member state, especially Germany with its tough data protection laws, customers can opt for convenience over privacy. But to be fair, it is the customer making the decision to expose his or her mail to government scanners. Nothing about the program is mandatory and it is solely the resident’s decision whether or not to enroll in the program.

While the program is only in its test phase, it raises not only privacy concerns but a host of data retention issues. How long will the digital images be stored and where?  Who will have access to the stored images? How will the images be discarded to ensure that bad actors won’t be able to reconstruct the digital images? What safeguards are employed in transmitting the customer’s email?

These are just a few of the questions that the program raises.

Deutsche Post’s foray into the digital delivery business is meant to keep pace with the private sector. U.S. news reports say that Deutsche Post has struggled to remain competitive in a digitized world.  There are other companies in Germany that offer similar scanning and mail services.

The U.S. has a variation of the German program – but it’s far less invasive. In 2017, the U.S. Postal Service started “Informed Delivery,” a program where the postal service scans the outside of letter-sized envelopes and then emails the image to the customer. The mail isn’t opened, nor are the contents exposed.