Submission Number: 00324
Received: 2/17/2011 2:40:03 PM
Commenter: Mitchell Long
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 detrimental affect on geospatial community.
Specifically, the FTC report imprecisely uses and regulates the term “precise geolocation information” or “precise geolocation data”. This would adversely impact my firm, job, and co-workers. Not to mention existing clients, potential consumers, other geospatial firms, and state and government programs. I am chiefly troubled that this term was not defined in the FTC staff report and the proposed regulations will have broad and damaging unintended consequences.
The use of the term “geolocation” or other geospatial relevant terminology that appear in the FTC regulations will impose a significant liability on my firm where I work. 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 halt or deem illegal, common, legitimate, and emerging uses of geospatial data for environmental protection, emergency response/post disaster remediation, E-911 & ambulance services, infrastructure design and maintanience, home security, navigation, airspace safety, just to mention a few.
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.