Airlines traveling to and from France will soon have a preview of the API-PNR Passenger Name Record initiative. And the UK has already introduced PNR with its e-borders initiative. So, how prepared would your airline be if a pan-European EU directive were to be passed into law by Brussels, or individual EU countries quickly introduced their own PNR variant?
Global flag carrier airlines with a PSS Passenger Service System might find that they already collect the datasets commonly requested in the PNR project (see the full list of prescribed datasets for France at the bottom this article). So their challenge is simply how to present that data in the required format, at the required pre- and post-takeoff intervals.
However, regional and low cost carriers often will not capture all the relevant datasets, especially when they are working with third party resellers. And they will certainly need a technology add-on to present their data to the relevant authority before and after flights have taken off.
So for airlines large and small, PNR compliance is an issue which should be on their risk management radar. In a fast moving and highly charged political atmosphere, it is easy to imagine a scenario where European lawmakers might accelerate their plans for enacting PNR regulations. And, of course, individual countries have the power to implement their own version of a Passenger Name Record legislation, practically overnight if the need arises.
Right now there is a weight of political and media argument in favor of a harmonized European Passenger Name Record standard.
For example, in a Dec 1st, 2015, article published by France’s Le Figaro (link below), the newspaper pointed out that France’s API-PNR initiative only collected data on passengers traveling to and from France. “In other words,” the Figaro story says, “someone who decides to travel by car from (France to) Berlin (then fly) to Istanbul escapes the radar screens of France.”
In Europe, both France and UK – with its e-borders initiative – have a form of PNR in place, as do Denmark and Sweden.
But the fact that individual countries can enact their own version of PNR has prompted many to suggest that the EU could – and should – fast-track a harmonized solution.
The website Airport Technology (link below) quoted Statewatch – a watchdog group which monitors anti-terrorist legislation – in their article:
“Given the absence of EU rules on PNR systems, ‘considerably diverging systems’ may be exactly what the Commission is funding,” the watchdog says. “Despite the apparently schizophrenic nature of this activity, it seems likely to work in the favour of EU PNR advocates – the more national PNR systems that are in place, the greater the impetus for a harmonised EU framework to govern them, in order to overcome ‘uneven levels of protection of personal data… security gaps… and legal uncertainty’”.
Of course, as part of their risk management process, the c-suite of airlines need to be aware of and plan for a harmonized EU PNR directive, and also be aware of the potential for national variants of the Passenger Name Record program to be introduced.
Conztanz specialises in data management for airlines and airports. We have worked with numerous airlines to implement PSS solutions.
We were also selected to work on the specification, implementation and certification of France’s API-PNR initiative.
This places Conztanz in a strong position to help all airlines to identify their PNR-ready status, and develop a plan for being certified by likely EU and potential EU member state PNR initiatives.
“As a specialist consulting company,” says Philippe Grandguillot, Senior Expert Consultant at Conztanz, “we can offer a custom PNR package for airlines. Our audit is a low-cost way for airlines to plan their technology and marketing response to PNR legislation, so they can quickly implement the plan as new laws are introduced.”
Grandguillot continues: “Some airlines have told us that other PNR technology solutions seem to be rigid and expensive, but in contrast our consulting-led package means our proven technology solution can be designed around the existing processes used by flag, regional and low-cost carriers.”
With the Conztanz consulting audit, airlines can simply develop a ‘what if’ PNR plan. There is no need to introduce the actual technology solution until it is actually needed. This gives the leanest, best value risk mitigation solution for PNR.
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PNR-1 Passenger Name Record Locator Number
PNR-2 Date of reservation/issue of ticket
PNR-3 Date(s) of intended travel
PNR-4 Name(s), date of birth
PNR-5 Address and Contact information (telephone number, e-mail address)
PNR-6 All forms of payment information, including billing address
PNR-7 All travel itinerary for specific PNR
PNR-8 Frequent flyer information
PNR-9 Travel agency /Travel agent
PNR-10 Travel status of passenger including confirmations, check-in status, no show or go show information
PNR-11 Split/Divided PNR information
PNR-12 General remarks (excluding personal data aimed by the second paragraph of #1 of L232-7 article of the code of the internal security)
PNR-13 Ticketing field information, including ticket number, date of ticket issuance and one-way tickets, Automated Ticket Fare Quote fields
PNR-14 Seat number and other seat information
PNR-15 Code share information
PNR-16 All baggage information
PNR-17 Number and other names of travellers on PNR
PNR-18 Any collected API information
PNR-19 All historical changes to the PNR listed in numbers 1 to 18