Submission Number: 00209
Received: 1/6/2011 9:45:49 AM
Commenter: Wesley Keller
Organization: City of Universal City
Agency: Federal Trade Commission
Initiative: A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"
Attachments: No Attachments
Page 61 Last paragraph of the report.
The proposed rule-making could have unintended consequences:
Would precise geolocation include land surveying in terms of platting requirements? Plats are public documents required by municipalities and local government. Platting commonly provides precise geolocation information.
Would it include records kept by tax appraisal districts? Title research and land surveying use the records to establish title, and research land records prior to a survey.
Would it include deed and plat records maintained by counties. Land surveyors rely on these records to do their jobs. These records are commonly maintained electronically.
What about aerial photography? Would a company have to receive permission from all the people within the coverage area of the photo?
Most of this information is retained in some form of electronic file or document. The need to share this information is intrinsic to the fields of remote sensing, photogrammetry, geographic information systems, land surveying, engineering and others.
There are privacy concerns with products such as Google Maps and Google Earth, but the benefits greatly outweigh those concerns.
Even personal geolocation is problematic: location information maintained by private telecommunications firms is used by first responders to respond to 911 calls in areas away from the home.
Most telecommunications devices allow the consumer to "turn off" the location features of the phone.
"Precise geolocation" needs a narrow definition. Perhaps something along the line of precise geolocation for the express purpose of tracking individual persons.
Thank you for your time.