The public transport network of a region inhabited by more than 4 million people is run by a complex interplay of public and private actors. Large amounts of data are generated by travellers, buying and using various forms of tickets and passes. Analysing the data is of paramount importance for the governance and sustainability of the system. This manuscript reports the early results of the privacy analysis which is being undertaken as part of the analysis of the clearing process in the Emilia-Romagna region, in Italy, which will compute the compensations for tickets bought from one operator and used with another. In the manuscript it is shown by means of examples that the clearing data may be used to violate various privacy aspects regarding users, as well as (technically equivalent) trade secrets regarding operators. The ensuing discussion has a twofold goal. First, it shows that after researching possible existing solutions, both by reviewing the literature on general privacy-preserving techniques, and by analysing similar scenarios that are being discussed in various cities across the world, the former are found exhibiting structural effectiveness deficiencies, while the latter are found of limited applicability, typically involving less demanding requirements. Second, it traces a research path towards a more effective approach to privacy-preserving data management in the specific context of public transport, both by refinement of current sanitization techniques and by application of the privacy by design approach.
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