SNCF’s Title Requirement Overturned After Legal Challenge
France’s top administrative court has ruled that SNCF, the national railway operator, can no longer require passengers to choose a gendered title like “Mr.” or “Ms.” when purchasing tickets online. The decision applies to both the official SNCF website and the SNCF Connect mobile app. The case was brought forward by LGBTQ+ advocacy group Mousse, which argued the practice was discriminatory and violated data protection laws. Even though SNCF had recently stopped enforcing the requirement, Mousse continued its legal action to ensure the practice was formally declared unlawful.
Council of State Cites GDPR Violation
The French Council of State stated that the mandatory selection of a courtesy title breached the General Data Protection Regulation (GDPR). Mousse argued that compelling users to disclose such personal information amounted to unnecessary and unjustified data processing. Before reaching its decision, the Council asked the Court of Justice of the European Union (CJEU) for guidance. In January 2025, the CJEU confirmed that collecting a customer’s title for the sake of marketing personalization does not qualify as essential for fulfilling a transportation service contract.
Data Minimization at the Heart of the Verdict
The CJEU based its response on the principle of data minimization, which requires companies to collect only the data strictly necessary to provide a service. The Council of State echoed this view, clarifying that while specific services—such as women-only sleeping compartments—might legitimately require gender data, this does not justify a broad policy requiring all users to submit gendered titles across SNCF Connect’s platforms.
No Valid Legal or Business Justification
The court concluded that SNCF had no legitimate business interest or contractual need to request titles from customers. It stated that “forcing customers to provide such personal data exceeds what is strictly necessary for the purposes claimed by SNCF Connect.” As part of its ruling, the court ordered the French state to pay €3,000 in legal expenses to the Mousse association.
Long-Running Complaint Results in Policy Change
The dispute originated from a complaint filed by Mousse with France’s data privacy watchdog, CNIL, which initially rejected the case in March 2021. Mousse then took the issue to the Council of State. In the meantime, SNCF updated its policy. “As of May, SNCF Connect no longer requires customers to provide a gendered title when purchasing tickets for travel within France,” the company announced in a statement shared with AFP. SNCF also noted that, as a ticketing platform, it follows the data collection guidelines set by its transport partners.
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