(c) justification and proportionality: it would seem that in practice, for law enforcement and security purposes, APIS data are more than sufficient; these data are already collected in Europe in accordance with Council Regulation (EEC) 2299/89, and may therefore be exchanged with the US under a comparable regime; behaviour data in the PNR seem to be of limited use, as they cannot be identified if not linked to APIS; the justification for the general transfer of PNR data is therefore not satisfactory;
c) pamatojums un proporcionalitāte;