Comments About “Anonymized” and “Deidentification” to FCC

Comments About “Anonymized” and “Deidentification” to FCC

Yesterday, the Federal Communications Commission posted FPF’s comments about “anonymization” and “deidentification.”  The comments come in response to a request from Public Knowledge that the FCC clarify whether “anonymized” or “deidentified” but non-aggregate call records constitute individually identifiable “customer proprietary network information” under Section 222 of the Communications Act.

FPF submitted  comments to address the argument that all anonymized records must be considered “personally identifiable” records because there have been instances in which some publicly available, anonymized records have been reidentified.  Public Knowledge argues that because researchers have been able to reidentify some publicly disclosed data sets that were purged of personally identifying information, all datasets that have been purged of personally identifying information must necessarily be considered individually identifiable.  FPF responded:

Logically, this argument is flawed. It is analogous to the argument that because some locks have been broken, there is no such thing as a reasonably secure door.

Although reidentification may be possible in some specific circumstances, when proper anonymization practices are used, anonymization is a valuable and effective way to advance the goal of protecting individual privacy while allowing for beneficial uses of data.  The full set of comments is available to read.

Leave a Reply


Privacy Calendar

Sep
15
Mon
all-day Big Data: A Tool for Inclusion or Exclusion? @ Constitution Center
Big Data: A Tool for Inclusion o… @ Constitution Center
Sep 15 all-day
The Federal Trade Commission will host a public workshop entitled “Big Data: A Tool for Inclusion or Exclusion?” in Washington on September 15, 2014, to [...]
Sep
17
Wed
all-day IAPP Privacy Academy and CSA Congress 2014 @ San Jose Convention Center
IAPP Privacy Academy and CSA Con… @ San Jose Convention Center
Sep 17 – Sep 19 all-day
This fall, the International Association of Privacy Professionals (IAPP) and Cloud Security Alliance (CSA) are bringing together the IAPP Privacy Academy and the CSA Congress [...]
Oct
21
Tue
6:00 pm Consumer Action’s 43rd Annual Awards Reception @ Google
Consumer Action’s 43rd Annual Aw… @ Google
Oct 21 @ 6:00 pm – 8:00 pm
To mark its 43rd anniversary, Consumer Action’s Annual Awards Reception on October 21, 2014, will celebrate the theme of “Train the Trainer.” Through the power of [...]
Jan
28
Wed
all-day Data Privacy Day
Data Privacy Day
Jan 28 all-day
“Data Privacy Day began in the United States and Canada in January 2008, as an extension of the Data Protection Day celebration in Europe. The [...]
Jan
28
Thu
all-day Data Privacy Day
Data Privacy Day
Jan 28 all-day
“Data Privacy Day began in the United States and Canada in January 2008, as an extension of the Data Protection Day celebration in Europe. The [...]

View Calendar