While eCall has some weak privacy protections (it's open to all the standard cellular network surveillance lawful in each country), it also means you cannot disable the vehicle's modem in most (maybe all) EU countries with failing roadworthiness checks and insurance policies.
Yes, I am sure.
Annex VII only rules out connecting to the PSAP/112 side, not routine network attaches. To detect faults in the “means of communication”, the IVS has to verify that the SIM, baseband and RF path are actually usable, and you can’t test that without a network attach.
In practice that’s what all current eCall implementations do. The modem attaches to the cellular network at each ignition so it can confirm it’s capable of placing an eCall. If you block the modem or antenna, the IVS fails its self-test and the vehicle is no longer roadworthy.
eCall mustn't be active until an accident occurs. The lawful interception lobby tried hard to turn every car into a free data point they could sell to the government, but their efforts have failed.
Last I heard they've shifted their efforts to making remote activation of on-board cameras part of the 5/6G smart car bullshit (which will of course be part of road safety requirments not long after).