Air Traffic Control Conversations Collection – A legal introduction by ELDA

ELRA, the European Language Resources Association, and its distribution agency, ELDA, have been funded in 1995 and have been a world-wide leading player in distributing Language Resources and providing other services to the speech language communities. In the course of the ATCO2 project, ELDA provides legal expertise for the collection of Air Traffic Control Conversations and Data Management in the project.

Air Traffic Control (ATC) Conversations  Collection – A Grey Area


ELRA plays a leading role in distributing and sharing Language Resources (LRs) within the Human Language Science and Technology Community. During the Atco2 project, ELDA draws on its experience and knowledge of the legal framework surrounding data collection in the context of Air Traffic Control Conversations. Regarding the field of Air Traffic Control, the legal framework is not as clear as one would expect. Indeed, Air Traffic enthusiasts do often listen to ATC conversations during personal time and for private uses. However it is not so simple to derive the feasibility of those private practices into a large scale collection of conversations.Whereas listening is not prohibited, as long as they do not interfere with the traffic and the signals, the status of recording has not been uniformally settled by legal texts and courts around the globe. From our first findings we can describe 3 kinds of situations :

  • Countries textually preventing recordings of ATC conversations: The United Kingdom, for instance, prevents the use of radio apparatus without licenses1. New Zealand prohibits the reproduction and distribution of contents of communications2

  • On the other hand, in the United States allows recording of Air Traffic Conversations since the Criminal Code explicitly states that interception of conversations transmitted by stations relating to aircrafts does not constitute an offence3.

  • For other countries, so far the situation has not been clarified. During the course of the project we will share a table with the community stating the legal status of recording in the countries where recordings are made, whenever sufficient information can be gathered.


ATC as public domain information

One of the hypotheses that could allow reproduction of ATC is to consider through general intellectual property principles that they are Public Domain, and therefore freely available to the general public.

We came to this hypothesis thanks to two characteristics of air traffic conversations:

  • ATC are broadcast over the radio in the public domain and with no explicit prohibition they could be listened or recorded by everyone.

  • Under the definition given under the major legal copyright systems they could not be considered as worthy of copyright protection since they serve a purely functional purpose and are limited by phraseology.

  • At the moment our findings cannot support this hypothesis especially in light with other pieces of restrictive legislation surrounding secrecy of correspondence.



ATC as Public Service Information

The second hypothesis that we could formulate would be more limited in its scope but could provide a useful base for collection and reuse of air traffic conversation. There is a trend that has been made mandatory by law, especially in the European Union, to make available data produced by pubic services and public administration in the course of their work. We could say that since ATC are recorded by Air Traffic Control Service Providers who are usually operated as a public service for airlines, we could also consider that the conversations recorded by those providers fall under the Public Sector Information Directive4 reworked and enacted in 2019, which allows users to claim from Public Administration a copy of the documents produced by the administration during its operation of a public service.



ATC as privately owned database

European legislation5 provides for sui generis rights to database producers as long as they prove a substantial investment in the creation of the database. ELDA is used to negotiating distribution rights with the LR owners and could therefore make such resources available under fair conditions and a clear legal framework. ELDA is also working on LR discovery and identification with a dedicated team that investigates and lists existing and valuable resources that are then negotiated on a case by case basis.

On top of clarification of legal status regarding the collection of ATC conversation ELDA can also provide guidance on metadata scheme and curation for the project.



 ATCO2 Data Management Plan and Metadata Scheme


 Main issues for Data Management in the project

Thanks to its experience in drafting data management plans related to projects related to speech data collection.Over the course of the project, ELDA will assist in the definition of the Data Management Plan that is required in all Horizon 2020 projects.

The main objective of this plan is to establish policies regarding data management over the course of the project and beyond. ELDA efforts around this plan are focused on the compliance of data management with the General Data Protection Regulation6 and Intellectual Property issues while complying with FAIR principles (Find-ability, Accessibility, Interoperability, and Re-usability).


A comprehensive metadata scheme

Finally ELDA also provides assistance during the project to design a comprehensive metadata scheme for the project taking into account all the specifications of the project especially location of the airports, time and date of recordings, recording equipment.

ELDA has contributed to widely adopted metadata schemes such as META-Share or ELRC which have been shared with the consortium and will be adapted to suit the needs of the projects.


 Speech Language Resources @ ELRA

Over the last decade, ELRA has compiled a large list of resources that constituted its Catalogue of LRs. ELRA has negotiated distribution rights with the LR owners and made such resources available under fair conditions and a clear legal framework.

As of June 2020, the ELRA Catalogue of Language Resources counts 1474 resources out of which 36% are Speech and Speech-related LRs. For those resources, the offer has grown steadily from 31 to 529 resources between 1996 and 2020, as shown in the graph.

The databases catalogued in the Speech LRs section of the ELRA Catalogue have been produced with speakers’ recordings made over the telephone (fixed or mobile) network, or through a microphone, they have been recorded in various environments, cover a wide range of speakers (female, male, native or non-native speakers of their language, children, etc.) and a large number of European and non-European languages, etc.

All these Speech resources are available from the ELRA Catalogue:



1 Wireless Telegraphy Act 2006, Sect. 8

2 Section 133A, Radiocommunications Act 1989

3 18 U.S Code §2511, 2(g)(i)

4 Directive EU 2019/1024 on open data

5 Directive 96/9/EC on the legal protection of databases

6 Regulation 2016/679