FTC has been hosting a series of seminars on consumer privacy, on which it has requested comments. The most recent seminar explored privacy issues related to mobile device tracking. As the seminar summary points out …
In most cases, this tracking is invisible to consumers and occurs with no consumer interaction. As a result, the use of these technologies raises a number of potential privacy concerns and questions.
The presentations raised an interesting and important combination of questions about how to promote business and economic innovation while protecting individual privacy. I have submitted a comment on these changes with some proposed recommendations.
To summarize (quoting from the submitted the comment):
Knowledge of an individual’s location history and associations with others has the potential to be used in a wide variety of harmful ways. … [Furthermore], since all physical activity has a unique spatial and temporal context, location history provides a linchpin for integrating multiple sources of data that may describe an individual. [R]esearch shows that human mobility patterns are highly predictable and that these patterns have unique signatures, making them highly identifiable– even in the absence of associated identifiers or hashes. Moreover, locational traces are difficult or impossible to render non-identifiable using traditional masking methods.
I invite you to read the full comment here:
This comment drew heavily on previous comments on proposed OSHA regulation made with colleagues at the Berkman Center, David O’Brien, Alexandra Woods, was made on behalf of the Privacy Tools for Research Project, of which we are a part, and has benefitted from extensive commentary by the other project collaborators.