Submission Number: 00293
Received: 2/11/2011 11:37:08 AM
Commenter: John Copple
Organization: Sanborn Map Company
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
I respectfully urge the FTC not to implement any enforcement or broad regulation that would have a harmful and detrimental affect on firms like mine in the broad private geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact consumers, geospatial firms, and government
programs. My firm is particularly concerned that this term was not defined in the FTC staff report and the proposed regulations will have broad and harmful unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant new liability on my firm. It regulates areas of the economy and geospatial activities that have not been identified as a problem or pose any privacy concern to citizens.
The regulations could thwart common, legitimate, and emerging uses of geospatial. For example the data is used today for urban planning,storm water management, agriculture management, broadband mapping, emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet
management, homeland security, navigation, mortgage foreclosure analysis, fire risk and property management and a myriad of other uses.
Moreover as currently stated the activities, technologies, and applications development related to geospatial could be deemed illegal. For example, it would be impractical, if not impossible, for my firm to obtain prior approval or consent from individual citizens
prior to acquiring or applying data such as satellite imagery, aerial photography, or parcel, address, or
transportation data. The FTC regulation would effectively ban my firm, or our clients (cities,counties, state governments, and native American tribes from realizing the value from geospatial data in important value-added, integration, and application activities my frim performs to provide these customers with information.
Finally, any such FTC regulation could put U.S. companies at a significant and insurmountable competitive
disadvantage against foreign firms that may not be covered by that regulation, or for which enforcement would be impractical.
FTC should provide the necessary and desirable privacy protections to individual citizens; however, it should not limit the geospatial community’s ability to grow, prosper, and bring to the market those technologies and applications that meet the economic demands of consumers and citizens.