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Today, Public Knowledge filed comments with the Federal Communications Commission highlighting privacy concerns raised by the “Roadmap for Improving E911 Location Accuracy” proposed by the Association of Public-Safety Communications Officials, the National Emergency Number Association, AT&T Mobility, Sprint, T-Mobile USA, and Verizon.
Multiple public interest groups join Public Knowledge in these comments, including: American Civil Liberties Union, Alvaro Bedoya, Benton Foundation, Center for Democracy & Technology, Center for Digital Democracy, Common Sense Media, Consumer Action, Consumer Federation of America, Consumer Federation of California, Consumer Watchdog, Electronic Frontier Foundation, Electronic Privacy Information Center, New America Foundation’s Open Technology Institute, Privacy Rights Clearinghouse, U.S. PIRG, and World Privacy Forum.
Public Knowledge and other privacy advocates point out a number of significant privacy-related concerns raised by the roadmap that have not been adequately addressed. For example, the roadmap proposes building a national database of physical addresses of wireless consumer home devices such as wi-fi routers and set-top boxes, but contains no information about how that database will be protected, and whether the database will be available to be shared with or sold to third parties.
In light of this and other newly raised concerns, Public Knowledge and privacy advocates urge the Commission to:
- pass regulations to protect the highly accurate location information that will be generated to meet improved E911 location accuracy standards
- require that representatives of consumer privacy organizations be allowed to participate fully in the further development of improved E911 location accuracy, and
- ensure that any final agreement(s) will be subject to further notice and comment
In the event the Commission moves forward with an Order in this docket without passing new privacy regulations, Public Knowledge and privacy supporters encourage the Commission to issue a Further Notice of Proposed Rulemaking on privacy.
The following quote can be attributed to Laura Moy, Staff Attorney at Public Knowledge:
“Improved E911 location accuracy has the potential to save thousands of lives. But improving the functionality of the E911 system should not come at the expense of privacy—nor does it have to. At the same time it issues final rules in this proceeding, the FCC should recognize the important privacy issues raised by this proposed roadmap for implementation, and ensure that consumer privacy is carefully safeguarded from the outset.
“It is in consumers’ best interest to have highly accurate location technology available to ensure help arrives in an emergency, but that information should be carefully protected, and should never be shared with third parties without consumers’ clear consent. Privacy concerns must not be an afterthought, but should instead be incorporated into the very design process of new location technologies.”
You may view the comments here.