Submission Number: 00263 

Received: 1/31/2011 9:36:48 AM
Commenter: Garth Lawrence
Organization: The Haruspex Group
State: Colorado
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
Submission Text
Having worked in the Geospatial profession for more than 35 years I feel it important to comment on the various efforts under way in the Federal government to create new "privacy" protections for citizens. These proposed rules apply to the collection, storage and use of certain data about individuals, including their address The rules use the term "precise geolocation data" and prevent any private firm from collecting, storing or using such data without the citizen's advance approval. This is an impractical and impossible requirement for private geo spatial firms. The Federal proposals are poorly written, do not define precise geolocation data, and have serious unintended consequences for industries and professions beyond those these Federal authorities are attempting to regulate. I understand that the geospatial industry association, MAPPS, has submitted comments to the FTC and Commerce Department opposing regulatory language that would limit the collection, sharing or use of "precise geolocation data". I fully support the MAPPS effort.