Submission Number: 00055
Received: 1/10/2012 3:19:25 PM
Commenter: Andrew Eatchel
Agency: Federal Trade Commission
Initiative: Face Facts: A Forum on Facial Recognition Technology; Project No. P115406
Attachments: No Attachments
An iPhone app that uses FR may be easy to avoid by anyone not wishing to be tracked if notice is given prior to installation but the act of simply walking past a camera equipped billboard or sorting through music samples at a kiosk capable of covertly taking a snapshot of the customer should not automatically subject one to biometric data collection/analysis. Laws must be enacted to prevent commercial enterprises from acquiring and more particularly, storing biometric information without the specific permission of a subject. Governments must not be allowed to collect biometrics from individuals without their permission either.
Some important points need to be made:
1. Among the rights guaranteed by our founders are life, liberty and the pursuit of a peaceful existence free from biometric data collection and tracking. The right to privacy is unalienable and the need for such a right is self evident. Biometric data is the property of the individual to whom it belongs. It is NOT part of the public domain.
2. Despite claims to the contrary, biometric systems can an WILL be hacked and biometric data of all kinds are subject to theft which WILL ultimately lead to new forms of identity theft. Any biometric data collected WILL ultimately end up in some government database(s).
3. Giving notice of bio-data collection is not enough. To guarantee choice, application of FR or any other biometric data collection technologies such as retina scanners for instance must not be made in situations where the general public - have to be - in order to live life in a normal fashion and perform every-day functions (e.g., banking, shopping, using various forms of public transportation, participating in recreational activities, etc.) unless provision is made for the person to voluntarily activate the technology by some overt action and the person is able to obtain access to the basic goods and services necessary to carry on normal life functions WITHOUT the bio-data collection. There are NO situations in which choice is unnecessary. Period!
4. Development and deployment of biometric technologies must be subject to the strictest possible controls and such technologies should be implemented, only in a way that makes them exceptional in their use rather than the accepted norm!