Data Protection in International Air Carriage: Legal Challenges, Regulatory Divergence, and
Opportunities for Resolution
As civil aviation operations increasingly depend on the timely exchange of passenger data across
borders, the legal and regulatory complexities of data protection have become a central concern for
States and industry stakeholders. This panel will not only examine these challenges in theory but will
also draw on real-world experiences to illustrate their practical impact. Panelists will show how
divergent national privacy laws, such as the GDPR and other regional frameworks, affect international
air carriage, particularly in relation to passenger name records (PNR), advance passenger information
(API), and other protected data. Through case examples and lessons learned, the discussion will
highlight how air carriers and authorities have grappled with conflicting obligations, operational
delays, and compliance risks in live… scenarios. Building on the findings of the recent ICAO survey of
Member States and the work of the ICAO Secretariat Study Group on Data Protection Laws (SSG-DPL),
the panel will share insights into how States are implementing data protection obligations, managing
cross-border compliance risks, and navigating tensions between privacy, sovereignty, and operational
continuity. Practical experiences will underscore the complexity of reconciling legal conflicts and
demonstrate opportunities for harmonization, mutual recognition, and enhanced regulatory
cooperation —all in support of secure and seamless air transportation.
Moderator:
Alejandro Piera, Partner, Guanes, Heisecke & Piera (GHP) Advocates, Paraguay
Panellists:
- Jasmin Fabré Jiménez, Legal Director, Civil Aviation Board (JAC), Dominican Republic
- Auguste Hocking, Director Legal Services Regulatory and Governance,
International Air Transport Association (IATA)
- Captain James Ball, Legal Committee Chair,
International Federation of Airline Pilots Association (IFALPA)
- Erika Varga, Legal Officer, ICAO LEB