A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers" #00409

Submission Number:
00409
Commenter:
Stephen Phipps
Organization:
Woolpert, Inc.
State:
Ohio
Initiative Name:
A Preliminary FTC Staff Report on "Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers"

I urge the FTC not to implement a broad regulation that would have a harmful affect on firms like mine in the broad private geospatial community. The current FTC draft language uses the terms 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 would limit common, legitimate, and emerging uses of geospatial data for emergency response/post disaster remediation, insurance, environmental protection, E-911 & ambulance services, fleet management broadband mapping, home security, navigation, mortgage foreclosure monitoring/early warning system, and others. Activities, technologies, and applications development would 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, from important value-added, integration and application activities. Please reconsider this broad reaching regulation.