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

Nov
7
Fri
all-day George Washington Law Review 201... @ George Washington University Law School
George Washington Law Review 201... @ George Washington University Law School
Nov 7 – Nov 8 all-day
Save the date for the GW Law Review‘s Annual Symposium, The FTC at 100: Centennial Commemorations and Proposals for Progress, which will be held on Saturday, November 8, 2014, in Washington, DC. This year’s symposium, hosted in[...]
Nov
11
Tue
10:15 am You Are Here: GPS Location Track... @ Mauna Lani Bay Hotel & Bungalows
You Are Here: GPS Location Track... @ Mauna Lani Bay Hotel & Bungalows
Nov 11 @ 10:15 am
EFF Staff Attorney Hanni Fakhoury will present twice at the Oregon Criminal Defense Lawyers Association’s Annual Sunny Climate Seminar. He will give a presentation on government location tracking issues and then participate in a panel[...]
Nov
12
Wed
all-day PCLOB Public Meeting on “Definin... @ Washington Marriott Hotel
PCLOB Public Meeting on “Definin... @ Washington Marriott Hotel
Nov 12 all-day
The Privacy and Civil Liberties Oversight Board will conduct a public meeting with industry representatives, academics, technologists, government personnel, and members of the advocacy community, on the topic: “Defining Privacy.”   While the Board will[...]
Nov
20
Thu
all-day W3C Workshop on Privacy and User... @ Berlin, Germany
W3C Workshop on Privacy and User... @ Berlin, Germany
Nov 20 – Nov 21 all-day
The Workshop on User Centric App Controls intents to further the discussion among stakeholders of the mobile web platform, including researchers, developers and service providers. This workshop serves to investigate strategies toward better privacy protection[...]
Dec
2
Tue
all-day IAPP Practical Privacy Series 2014
IAPP Practical Privacy Series 2014
Dec 2 – Dec 3 all-day
Government and FTC and Consumer Privacy return to Washington, DC. For more information, click here.
Dec
11
Thu
9:00 am Progress of the EU Data Protecti...
Progress of the EU Data Protecti...
Dec 11 @ 9:00 am
The EU Member States have agreed to conclude the negotiations on the EU Data Protection draft Regulation in 2015. The process will have arrived at a critical point by the end of this year. The[...]

View Calendar