Submission Number: 00225
Received: 1/12/2011 11:49:30 AM
Commenter: Thomas Hardin
Organization: Southern Engineering & Surveying, Inc.
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
It appears to us at this firm that the language of this regulation is too broad, especially as it pertains to the term "precise geolocation data." While this phrase is used it is not defined. That leaves the term open to wide interpretation which could be used against any and/or all agencies, business, or firms that employ such data. Also the regulation requires any geospatial firm to get "affirmative express consent" from every citizen about whom precise geolocation data is to be collected. That is an impractical to the point of being impossible. This regulation needs to be rewritten to remove the term(s) "precise geolocation data." After all, at least in Georgia, this data is already a matter of public record. All one has to do is to go to the local tax commissioner's office, and look it up.