EPIC Alert 19.14
E P I C A l e r t
Volume 19.14 July 30, 2012
Published by the
Electronic Privacy Information Center (EPIC)
"Defend Privacy. Support EPIC."
Table of Contents
 EPIC Demands Evidence of TSA Body Scanner Rulemaking
 EPIC Asks Congress to Adopt Privacy Safeguards for Drones
 EPIC to FCC: Require Mobile Phone Carriers to Protect Privacy
 EPIC Recommends Protections re: Commercial Face Recognition
 In UK, Google Admits It Retained Street View Data
 News in Brief
 EPIC in the News
 Book Review: 'How to Be Invisible,
 Upcoming Conferences and Events
TAKE ACTION: Require the TSA to Follow the Law!
- SIGN the Petition: http://epic.org/redirect/071612-tsa-sign.html
- READ about EPIC v. DHS: http://epic.org/redirect/071612-epicvdhs.html
- SUPPORT EPIC: http://www.epic.org/donate/
 EPIC Demands Evidence of TSA Body Scanner Rulemaking
EPIC has submitted a Freedom of Information Act request to the
Transportation Security Administration, seeking documents that indicate
whether the agency intends to provide the
opportunity for public
commentary on the controversial airport body scanner program. According
to DHS documents, the TSA "staff
responsible for drafting the proposed
rule indicated [that] they had an initial, very preliminary draft
prepared by August 11,
2011. . ." EPIC's FOIA request seeks disclosure
of this document.
One year has passed since the DC Circuit Court of Appeals ordered
TSA to "act promptly" and undertake a public notice-and-comment
rulemaking. The court's ruling followed EPIC's lawsuit against
which claimed that the agency had violated federal law by making the
body scanners primary screening technology without public
The court noted that "few if any regulatory procedures impose
directly and significantly upon so many members of the public,"
ordered DHS to "act promptly on remand to cure the defect of its
promulgation" of the body scanner program. More than a year
DHS has not published the rule or accepted public comments on airport
body scanners - nor has it given any indication of
a date when it will
In a separate Petition for Writ of Mandamus, EPIC asked the DC Circuit
Court to require the agency
to issue a proposed rule within 60 days or
suspend the scanner program. EPIC's petition argues that DHS's failure
to publish a
rule constitutes unreasonable agency delay, and that the
court should order DHS to issue a public rule within 60 days, or else
suspend the agency's rule pending the APA rulemaking procedure required
by law. EPIC's petition also states that DHS's failure to
the mandate shields the screening program from judicial review under
the APA and leaves the matter in "administrative
An online petition posted on the "We the People" website demands that
the White House "Require the Transportation Security
to Follow the Law!" Many organizations support the petition and other
efforts to enforce the 2011 court order that
the TSA comply with APA
EPIC: FOIA Request to Department of Homeland Security (Jul. 18, 2011)
EPIC: Petition for Writ of Mandamus re: Body Scanners (Jul. 17, 2012)
White House Petition: "Require the TSA to Follow the Law!"
EPIC: EPIC v. DHS (Suspension of Body Scanner Program)
EPIC: Whole Body Imaging Technology and Body Scanners
 EPIC Asks Congress to Adopt Privacy Safeguards for
EPIC testified July 19 at a US House Homeland Security
Subcommittee hearing on "Using Unmanned Aerial Systems Within the
Homeland: Security Game Changer?". The hearing examined
federal use of
drones within the US.
EPIC Associate Litigation Counsel Amie Stepanovich testified on the
of domestic drone use, stating that "the privacy
and security concerns arising from the use of drones needs to be
calling for specific legislative safeguards to limit
A 2012 re-authorization bill for the Federal Aviation
requires the agency to develop rules governing the operation of drones
within the United States. In February, EPIC,
joined by over 100
organizations, experts, and members of the public, petitioned the FAA
to begin a rulemaking on the privacy impact
of drone use. The agency
has yet to respond to EPIC's petition or address other privacy
concerns. EPIC previously recommended that
the FAA develop privacy
rules, that DHS conduct a privacy assessment, and that Congress
establish new privacy safeguards.
US Bureau of Customs and Border Protection owns 10 Predator drones
to operate along US borders at a cost of approximately $18 million
each, with an additional $55.3 million total for maintenance and
operations. A recent report by the DHS Office of the Inspector
General concluded that Customs and Border Protection "needs to
improve planning of its unmanned aircraft systems program to address
its level of operation, program funding, and resource requirements,
along with stakeholder needs." Despite the CPB's limited mission
safeguard the borders, the report demonstrated that CPB often flies
missions for the FBI, the Defense Department, local law
and other agencies. This practice made headlines in 2011 when police
in North Dakota used a CPB drone to arrest a
Senator Rand Paul (R-KY) and Rep. Austin Scott (R-TX) have introduced
bills in the Senate and the House designed to
limit the use of drones
or surveillance within the US. The bills would require law enforcement
to receive a warrant before conducting
any criminal surveillance of
US House: Hearing on Drones and Homeland Security (Jul. 19, 2012)
EPIC: Testimony on Drones before US House (Jul. 19, 2012)
EPIC: Unmanned Aerial Vehicles (UAVs) and Drones
FAA: 2012 Air Transportation Modernization and Safety Improvement Act
EPIC: APA Petition to the FAA (Feb. 24, 2012)
DHS Office of Inspector General: Drone Report (May 30, 2012)
US House: Preserving Freedom from Unwarranted Surveillance Act of 2012
 EPIC to FCC: Require Mobile Phone Carriers to Protect
EPIC, joined by the group Consumer Watchdog, has
submitted comments to
the Federal Communications Commission on the privacy and security of
information stored on mobile phones.
The comments discuss the various
privacy risks, including more collection of consumer data, created by
the business practices of
many carriers, and they recommend that the
FCC require mobile carriers to implement "clear, comprehensive, and
privacy and security protections based on Fair
The FCC had already requested comments on numerous issues,
whether consumers were given meaningful notice and choice with respect
to service providers' collection of usage-related
information on their
devices, and whether providers' current practices were potentially
detrimental to consumer privacy and data
security. EPIC's comments
list several practices employed by carriers that create privacy and
security risks for consumers, including
"price discrimination on the
basis of consumer profiles" collected by commercial mobile
surveillance, or carriers making "ordinarily
accessible to law enforcement officials" without a search warrant.
EPIC's comments recommend that the FCC require
carriers to implement
specific practices. For example, carriers should obtain, at the time
of data collection, consumer consent
to share data with third parties;
limit the use of such data to the purposes stated at the time of
collection; and oblige carriers
to inform customers of the identities
of every affiliate, agent, or entity to which personal information has
been disclosed. EPIC
also recommends that the agency force carriers
"to provide reasonable access to personal data stored about
customers], as well
as create an easily navigable mechanism to
correct inaccurate information and request the removal of data."
In 2007 comments to
the FCC, EPIC called for increased protections for
customers' Customer Proprietary Network Information, and in 2001 EPIC
the FCC to establish fair location information practices. EPIC's
recent comments to the Federal Trade Commission on mobile advertising
disclosures stressed that mobile platforms heighten the problems
already inherent in notice-centric approaches to privacy.
Comments to FCC on Mobile Privacy (Jul. 13, 2012)
FCC: Request for Comments on Mobile Privacy (Jun. 13, 2012)
EPIC: Comments to FTC on Mobile Privacy (Jul. 11, 2012)
EPIC: Comments on FTC Workshop on Mobile Disclosure (May 11, 2012)
EPIC: Comments to FCC on CPNI (Jul. 2007)
EPIC: Comments to FCC on Fair Information Practices (Apr. 2001)
EPIC: Customer Proprietary Network Information
EPIC: Location Privacy
The White House: Consumer Privacy Bill of Rights (Feb. 2012)
FTC: "Protecting Consumer Privacy in an Era of Rapid Change" (2012)
 EPIC Recommends Protections re: Commercial Face Recognition
The Senate Judiciary Committee Subcommittee on Privacy,
the Law held a July 18 hearing to address "What Facial Recognition
Technology Means for Privacy and Civil Liberties."
called two panels of witnesses to discuss the impact of facial
The first panel included
representatives from the Federal Bureau of
Investigation and the Federal Trade Commission. The second panel
included EPIC Advisory
Board member Alessandro Acquisti, other
researchers in the fields of biometrics and science policy, and
representatives from Facebook
and the National Sheriffs' Association.
As Sen. Al Franken (D-MN) made clear in his opening statement at the
hearing, the use
of facial recognition technology requires careful
consideration because "biometric information is already among the most
of our private information, mainly because it is both unique
and permanent." Unlike a password, you cannot change your face, or
resulting "faceprint" created by facial recognition technology. While
there are many legitimate uses of this technology, Franken
others "should give us pause." Franken also commented that Facebook
"may have created the world's largest privately-held
faceprints - without explicit consent of its users."
In a statement for the record, EPIC called on the Subcommittee
protect individuals' ability to control the disclosure of their
identity, and that Fair Information Practices be enforced against
companies that collect facial recognition data. These legal
obligations would include limitations on collection, use, and
of the data, informed consent, security, accessibility,
and accountability. "In the absence of guidelines and legal standards,
recommends a moratorium on the commercial deployment of facial
In 2011, EPIC filed a complaint with the
FTC against Facebook's facial
recognition technology, stating that Facebook created biometric
profiles of users without their explicit
consent, failed to provide a
clear mechanism for the deletion of these profiles, and failed to take
adequate safeguards to ensure
that users' biometric information would
not be accessible to government agents and other third parties.
US Senate: Hearing on
Facial Recognition (Jul. 18, 2012)
Sen. Al Franken: Statement at Senate Hearing (Jul. 18, 2012)
Prof. Alessandro Acquisti: Statement at Hearing (Jul. 18, 2012)
EPIC: Statement at Facial Recognition Hearing (Jul. 18, 2012)
EPIC: Facial Recognition
EPIC: Facebook and Facial Recognition
 In UK, Google Admits It Retained Street View Data
In a recent letter to the UK Information Commissioner,
admitted it retained payload data improperly collected by Street View
vehicles. Google had promised earlier it would
delete the data. The UK
privacy commissioner's office has now demanded that Google turn over
the payload data for examination and
Europe, the UK, Israel, and some Asian countries have led the US in
their investigations of and resultant cases
against Google Street View.
Since their worldwide deployment in 2007, Google Street View vehicles
had obtained a vast amount of
Wi-Fi data from Wi-Fi receivers that
were concealed in the Street View vehicles. Google now concedes that it
gathered MAC addresses
(the unique device ID for Wi-Fi hotspots) and
network SSIDs (user-assigned network ID names) tied to location
private wireless networks. Google also admits that
it has intercepted and stored Wi-Fi transmission data, which includes
passwords and content.
Earlier in 2012, the Federal Communications Commission fined Google
$25,000 for obstructing an investigation
of Google Street View's
potential violation of federal wiretap law. The Commission found that
Google impeded by "delaying its search
for and production of responsive
emails and other communications, by failing to identify employees, and
by withholding verification
of the completeness and accuracy of its
submissions." In May 2010, EPIC wrote to the FCC and urged the agency
to undertake an investigation
after it became clear that Google had
intercepted the private communications of millions of users of Wi-Fi
networks in the United
States. Shortly afterward, the head of the FCC
Bureau of Consumer and Governmental Affairs wrote that Google's
infringes on consumer privacy."
EPIC has continued to press the FCC to follow through on investigations
of Street View via Freedom
of Information Act requests, "friend of the
court" briefs in Street View-related cases, and letters to other
government officials and agencies. In
2011, EPIC filed a "friend of
the court" brief in a US federal appeals court, arguing that Google
Street View violated federal
Google: Letter to UK Info. Office re: Street View Data (Jul. 27, 2012)
UK Information Commissioner's Office: Letter to Google (Jul. 27, 2012)
FCC: Settlement with Google re: Google Street View (Apr. 13, 2012)
EPIC: Letter to FCC re: Street View (May 21, 2010)
FCC: Blog Post on Google Street View (Jun. 11, 2010)
EPIC: "Friend of the Court" Brief re: Street View (Apr. 11, 2011)
EPIC: Investigations of Google Street View
EPIC: FCC Investigations of Google Street View
EPIC: Ben Joffe v. Google
 News in Brief
London Olympics Underway, Privacy Issues Loom
Olympic organizers have stepped up the use of surveillance and
at the London 2012 games. Body scanners
have been installed at entrances to Hyde Park and Victoria Park. IOC
members, VIPs, guests,
and staff will carry RFID-enabled identity
documents. One commentator has noted that even the Olympic Mascot has
"A Huge Camera
Eye That 'Records Everything.'"
Forbes: Post on London Olympics 2012 Surveillance (May 17, 2012)
EPIC: Privacy and the 2008 Olympic Games
EPIC: Body Scanners
FISA Reform Proposal Moves Forward in Senate
The US Senate Judiciary Committee has approved a bill that establishes
for the Foreign Intelligence Surveillance Amendments
Act. The Act provides for court approval of "programs of surveillance"
allow for the collection of communications of US citizens. The
bill, sponsored by Senator Patrick Leahy (D-VT), would renew the
but also establish new reporting requirements to improve government
accountability. In May 2012, EPIC Executive Director Marc
testified before the House Judiciary Committee, and recommended
increased oversight and reporting.
US Senate: Bill
to Extend Amendments to FISA Act
GovTrack: Text of FISA Amendments Act of 2008
EPIC: Statement before US House re: FISA Amendments (May 31, 2012)
EPIC: Foreign Intelligence Surveillance Act (FISA)
EPIC: Clapper v. Amnesty Int'l USA
Second Wisconsin Judge Strikes Down State Voter ID Law
In a second challenge to Wisconsin's voter ID requirement, Judge David
Flanagan has held that the ID law imposes an unconstitutional burden on
the right to vote. The law "tells more than 300,000 Wisconsin
who do not now have an acceptable form of photo identification that
they cannot vote unless they first obtain a photo ID
card," wrote Judge
Flanagan, upholding his March 2012 decision in the case NAACP of
Milwaukee v. Gov. Scott Walker. Flanagan's
opinion follows a similar
ruling earlier this year by Wisconsin judge Richard Niess.
Dane County, WI: Clerk of Courts
Dane County, WI: First Ruling on Voter ID Requirement (Mar. 15, 2012)
Dane County, WI: Additional Ruling on Voter ID Requirement
EPIC: Voter Photo ID and Privacy
EPIC: Crawford v. Marion County
Voters Wary of Individually Tailored Political Ads
A report by the Annenberg School for Communication at the University of
found that 86% of voters did not want political campaigns
to tailor advertisements based on their interests. This percentage is
higher than the percentage of respondents who reject other tailored
advertisements (61%) or tailored news (56%). Significantly,
of respondents also reported that they would be less likely to vote for
candidates that targeted them with tailored
Annenberg School: Report on "Tailored" Pol. Advertising (July 2012)
EPIC: Voter Privacy
EPIC: Public Opinion on Privacy
 EPIC in the News
"The Public Is Left in the Dark When Courts Allow Electronic
Surveillance." The New York Times, July 23, 2012.
"Aerial drones vulnerable to being hacked, Congress told." CNN, July
"McCaul: DHS Ignoring Drone Dangers." National Journal, July 19, 2012.
"Senator questions Facebook exec about facial-recognition feature."
Los Angeles Times, July 19, 2012.
"EDITORIAL: TSA defies the courts - Rogue agency refuses to comply
with the law." The Washington Times, July 18, 2012.
"Personal info tapped with an app." USA Today, July 18, 2012.
"TSA Fails to Comply With Year-Old 'Nude' Body-Scanner Court Order."
Wired, July 16, 2012.
"FBI Shopping for Social Networking Eves-dropping Software." Digital
Journal, July 15, 2012.
"White House order on emergency communications riles privacy group."
Computerworld, July 10, 2012.
For More EPIC in the News:
 Book Review: 'How to Be Invisible: 3rd Edition'
"How to Be Invisible: 3rd Edition," J. J. Luna.
J. J. Luna lives in one hell of a paranoid world. The former Franco-era
subversive turned privacy and security consultant firmly
the lives of average Americans are one step away from being decimated
by stalkers, government agents, and private
enormously popular and influential manual "How to Be Invisible" - now
in a brand-new 3rd Edition to include
mobile devices, social
networking, and more international content - is as disturbing and
anxiety-provoking as it is fascinating.
Even privacy advocates may be
stunned by a book whose fundamental recommendations are to "never, ever
let anyone other than your
closest friends know where you really live,"
and that if you "have ever received a letter or package at your present
your real name, the only way to protect your privacy is
"How to Be Invisible" categorizes personal privacy and anonymity
four levels, which Luna has determined based on how much money and
experience a private investigator would need to track you
down. Level 1
is "basic" and "economical" and according to Luna "will give you more
privacy than 98 percent of the general population";
Level 4 duplicates
the Federal Witness Security Program. Meanwhile, depending on what you
can stomach, Luna suggests putting your
car registration into the name
of a third-party LLC, renting a property pre-paid in cash, distrusting
your neighbors, and discouraging
a college education for your
offspring, because "all privacy will be lost until they graduate or
drop out." (This last is from
the chapter "Cool Stuff That Did Not Fit
Luna, however, is quite reasonable in the area of digital privacy.
he's a fan of pseudonyms, encryption, and the cash-based
anonymity of Craigslist, he also recommends basic electronic privacy
like avoiding clicking on online ads or responding to
unsolicited email; researching anyone you meet online; and eschewing
for anonymous, disposable prepays.
Previous critiques of "How to Be Invisible" have centered around two
issues: the book's American
focus, and Luna's advocacy of practices
that, while following the letter of the law, are often construed as
underhanded and duplicitous.
Luna has largely remedied the first
complaint by including a chapter on "International Privacy 101," and
providing more examples
of international privacy issues within the
main text. On the other hand, Luna is still advocating scrubbing out
the birthdate on
your passport, creating "shadow" addresses or
businesses that hide your true identity and profession, always
operating on a cash-only
basis, and even blatantly lying to get
someone off your trail - one chapter is called "When Is a Lie Not
best to think of Luna as an ideologue, a strident
street preacher whose practical tips to avoid eternal privacy
damnation can be
adapted to fit your own privacy-imperfect life.
In the meantime, please, for the love of God, turn off the .EXIF
settings on your
digital camera before your post your photos on
Facebook. There are people watching.
-- EC Rosenberg
"Litigation Under the Federal Open Government Laws 2010," edited by
Harry A. Hammitt, Marc Rotenberg, John A.
Verdi, Ginger McCall, and Mark
S. Zaid (EPIC 2010). Price: $75
Litigation Under the Federal Open Government Laws is the most
comprehensive, authoritative discussion of the federal open access
This updated version includes new material regarding President Obama's
2009 memo on Open Government, Attorney General Holder's
March 2009 memo
on FOIA Guidance, and the new executive order on declassification. The
standard reference work includes in-depth
analysis of litigation under:
the Freedom of Information Act, the Privacy Act, the Federal Advisory
Committee Act, and the Government in the Sunshine Act. The fully updated
2010 volume is the
25th edition of the manual that lawyers, journalists
and researchers have relied on for more than 25 years.
"Information Privacy Law: Cases and Materials, Second Edition" Daniel
J. Solove, Marc Rotenberg, and Paul Schwartz. (Aspen 2005).
This clear, comprehensive introduction to the field of information
privacy law allows instructors to enliven their teaching of fundamental
concepts by addressing both enduring and emerging controversies. The
Second Edition addresses numerous rapidly developing areas of
law, including: identity theft, government data mining and electronic
surveillance law, the Foreign Intelligence Surveillance
intelligence sharing, RFID tags, GPS, spyware, web bugs, and more.
Information Privacy Law, Second Edition, builds a cohesive
for an exciting course in this rapidly evolving area of law.
"Privacy & Human Rights
2006: An International Survey of Privacy Laws
and Developments" (EPIC 2007). Price: $75.
This annual report by EPIC and Privacy International provides an
overview of key privacy topics and reviews the state of privacy
75 countries around the world. The report outlines legal protections,
new challenges, and important issues and events relating
Privacy & Human Rights 2006 is the most comprehensive report on privacy
and data protection ever published.
"The Public Voice WSIS Sourcebook: Perspectives on the World Summit on
the Information Society" (EPIC 2004). Price: $40.
This resource promotes a dialogue on the issues, the outcomes, and the
process of the World Summit on the Information Society (WSIS).
reference guide provides the official UN documents, regional and
issue-oriented perspectives, and recommendations and proposals
future action, as well as a useful list of resources and contacts for
individuals and organizations that wish to become more
involved in the
"The Privacy Law Sourcebook 2004: United States Law, International
and Recent Developments," Marc Rotenberg, editor (EPIC 2005). Price:
The Privacy Law Sourcebook, which has been called the "Physician's Desk
Reference" of the privacy world, is the leading resource
attorneys, researchers, and journalists interested in pursuing privacy
law in the United States and around the world.
It includes the full
texts of major privacy laws and directives such as the Fair Credit
Reporting Act, the Privacy Act, and the OECD
Privacy Guidelines, as
well as an up-to-date section on recent developments. New materials
include the APEC Privacy Framework, the
Video Voyeurism Prevention Act,
and the CAN-SPAM Act.
"Filters and Freedom 2.0: Free Speech Perspectives
on Internet Content
Controls" (EPIC 2001). Price: $20.
A collection of essays, studies, and critiques of Internet content
filtering. These papers are instrumental in explaining why filtering
threatens free expression.
EPIC publications and other books on privacy, open government, free
expression, and constitutional values can be ordered at:
EPIC also publishes EPIC FOIA Notes, which provides brief summaries of
interesting documents obtained
from government agencies under the
Freedom of Information Act.
Subscribe to EPIC FOIA Notes at:
 Upcoming Conferences and Events
"Airport Body-Scanning: Will TSA Follow the Law?" 19 July 2012,
Washington, DC. For More Information: http://www.cato.org/event.
2012 ASAP Training, with Focus on FOIA and Privacy. 1-3 August 2012,
Washington, DC. Registration Closes July 27. For More Information:
CONSENT policy conference: "Perceptions, Privacy and Permissions:
the role of consent in on-lineservices." 6-7 September 2012,
Cluj-Napoca, Romania. Call for papers by 7 June 2012. For More
DataCenter Dynamics Converged. 12 September 2012, Washington, DC. For
More Information: http://www.datacenterdynamics.com/conferences/2012/
3rd Annual Privacy, ATI and Security Congress. 4-5 October 2012,
Ottawa, ON. For More Information: http://www.rebootconference.com/
Amsterdam Privacy Conference. 7-10 October 2012, Amsterdam. For More
34th International Conference of Data Protection and Privacy. 23-25
October 2012, Punta del Este, Uruguay. For more information:
The Public Voice Conference. 22 October 2012, Punta del Este, Uruguay.
For more information: http://www.thepublicvoice.org/.
PIPA Conference 2012: "Privacy on the Go." 1-2 November 2012, Calgary,
Alberta. For More Information: http://privacyconference2012.ca.
"Computers, Privacy and Data Protection: Reloading Data Protection."
23-25 January 2013, Brussels. For More information:
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