Submission Number: 00292
Received: 2/11/2011 7:04:22 AM
Commenter: Ken Fleming
Organization: Coleman Caldwell Co., LLC
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
As a geospatial professional, I strongly urge FTC to not implement any enforcement or general regulation that will have a serious affect on us in the geospatial profession.
The FTC report uses the term "precise geolocation information" or "precise geolocation data" which is not defined and could have broad and harmful unintended consequences. this term would increase our liability and drive costs up which will impact government agencies.
The ramifications of this proposal will impact emergency response, insurance, environmental protection, fleet management broadband mapping, home security, navigation, mortgage foreclosure systems, and many others. In addition, activities, technologies, and applications development could 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 me, or our clients, from important value- added, integration and application activities.
In a global economy, this regulation would put us at a competitive and insurmountable disadvantage against foreign firms that are not covered by this regulations. I understand FTC should provide necessary and desirable 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.
Thank you for your consideration