Submission Number: 00294
Received: 2/11/2011 12:33:56 PM
Commenter: Alan Mikuni
Organization: Towill, 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
My company is involved in the acquisition and manipulation of surveying and mapping data, that is, geospatial information. The work of Towill, Inc., and our colleagues in the geospatial community involves collection of aerial and space imagery and mapping information and data over many hundreds, perhaps, thousands of square miles of land surface, which likely encompass the holdings of hundreds, or thousands, perhaps, millions, of American citizens. The nature of Towill's business is to acquire and process accurate (precise) and reliable geospatial data (geo-location and descriptive information about features on the surface of the Earth), so that our customers and clients will be able to use the information in their day-to-day decision-making processes.
I understand the importance of FTC's mandate to provide necessary and desirable privacy protections to individual American citizens, but the tenets of your proposed "privacy" rule will impinge on my company's ability to conduct business. The terminology, "precise geolocation data", if it is not adequately defined, could be interpreted as exactly what my company acquires and processes. The need to obtain prior approval of citizens in order for firms like mine to acquire "precise geolocation data" about them and their property will pose near-impossible logistical and, likely, expensive challenges. Broad terms like "precise geolocation data" must be precisely defined before regulations like that you are proposing can be implemented. The implications of enactment using a broad-brush and imprecise definition can be a detriment to many sectors of the American economy, most specifically, geospatial firms like Towill, Inc., and other firms represented by the Management Association for Private Photogrammetric Surveyors (MAPPS). I respectfully urge the FTC not to implement an enforcement or broad regulation that would have a harmful affect on firms like mine.
Alan Mikuni, PE CP
a member of MAPPS.