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EPIC Alert 20.20 [2013] EPICAlert 20

EPIC Alert 20.20

======================================================================= E P I C A l e r t ======================================================================= Volume 20.20 October 16, 2013 ----------------------------------------------------------------------- Published by the Electronic Privacy Information Center (EPIC) Washington, D.C. "Defend Privacy. Support EPIC." ========================================================================= Table of Contents ========================================================================= [1] EPIC Appeals Secrecy of Body Scanner Radiation Documents [2] Gov. Brown Signs New California Privacy Laws [3] EPIC FOIA Docs Shed Light on Secret FBI Mobile Phone Tracking Team [4] Court Rules that Gmail Case Can Go Forward [5] EPIC Urges Congress on Student Privacy after Court Decision [6] News in Brief [7] EPIC in the News [8] EPIC Bookstore [9] Upcoming Conferences and Events TAKE ACTION: Tell Facebook: "Stop Changing Our Privacy Settings!" - READ about the Changes: - LEARN More about Facebook Privacy: - SUPPORT EPIC: ======================================================================== [1] EPIC Appeals Secrecy of Body Scanner Radiation Documents ======================================================================== EPIC has challenged two decisions by a federal district court which allow the Department of Homeland Security and the Transportation Security Administration to withhold factual information about airport body scanners, including test results, fact sheets, and estimates of radiation risks. In the opening brief to the court, EPIC argued that federal agencies may not withhold factual information under the "deliberative process privilege" in the Freedom of Information Act. EPIC maintained that "under the standard adopted by the lower court, not only would the judgment of agency officials be exempt, but so too would reports or studies of any significance." The challenge combines two separate cases EPIC appealed to the DC Circuit. EPIC filed a motion to consolidate both appeals because they raise substantially similar legal issues. EPIC then presented the issue of whether the lower court erred in failing to apply the "inextricably intertwined" test before determining that records could be withheld in full despite containing non-deliberative and factual materials normally released under the Freedom of Information Act. The two cases combined in EPIC's appeal also include a case against the Department of Homeland Security. That FOIA lawsuit sought records on the radiation risks posed by body scanners. The other FOIA lawsuit, against the Transportation Security Administration, sought to obtain agency records that detailed the operation and capabilities of the "Automated Targeting Recognition" software used on body scanners. According to the government Automated Targeting Recognition software allows TSA agents to see only a generic human image rather than the traveler's naked body. After several EPIC lawsuits and an act of Congress, TSA was required to adjust the devices to produce only generic images. However, earlier in 2013 the TSA was finally forced to unplug and box up the backscatter x-ray body scanners after the agency could not meet the Congressional mandate. The TSA was also required to take public comments on the use of body scanners after EPIC sued the agency for the unilateral decision to make body scanners the primary screening technique in US airports - a rule change that violated the Administrative Procedures Act. EPIC: EPIC v. DHS - Body Scanner FOIA Appeal EPIC: Opening Brief in EPIC v. DHS (Oct. 1, 2013) EPIC: EPIC v. DHS - Full Body Scanner Radiation Risks EPIC: EPIC v. TSA - Body Scanner Modifications (ATR) EPIC: Comments to TSA re: Passenger Screening Using AIT (June 24, 2013) DC District Ct.: Decision in EPIC v. DHS (Scanners) (Mar. 7, 2013) DC District Ct.: Decision in EPIC v. DHS (PowerPoint) (Mar. 7, 2013) EPIC: Initial Documents from DHS re: Body Scanners (Feb. 11, 2013) EPIC: EPIC v. DHS: Suspension of Body Scanner Program Whole Body Imaging Technology and Body Scanners ======================================================================== [2] Gov. Brown Signs New California Privacy Laws ======================================================================== California Governor Jerry Brown (D) has signed three state privacy bills into law. Assembly Bill 370 amends the California Online Privacy Protection Act by requiring that businesses disclose how they respond to Do Not Track signals or other mechanisms used by consumers to prevent the surreptitious collection of their browsing history. Senate Bill 568 provides for an "eraser button" that would require websites to allow minors to remove their own information. Finally, Senate Bill 255 prohibits "revenge porn," or the posting of explicit images or videos without the victim's consent. California law already requires website operators to post links to their privacy policies. AB 370 expands the disclosure requirement to include the website's response to Do Not Track signals. Although a Do Not Track standard has yet to be implemented, the law's disclosure requirements apply broadly to any "mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer's online activities . . . ." SB 568 contains an "eraser button" provision that requires a website or mobile app to allow registered minors to remove their content or information. The law has been compared to the federal Children's Online Privacy Protection Act and the "right to be forgotten" in the EU's proposed data protection regulation. However, SB 568 differs from COPPA in that it applies to users under age 18, whereas COPPA only applies to users under age 13. Additionally, minors may only delete information they post themselves, not information posted by a third party. SB 255 criminalizes the publication of intimate photos or videos that were originally produced "under circumstances where the parties agree or understand that the image shall remain private" if the publication was intended to, and in fact causes, "serious emotional distress." The law is intended to prevent "revenge porn" and is the first of its kind in the nation. In 2008, EPIC and a coalition of consumer privacy organizations successfully forced Google to place a prominent link on its homepage to the company's privacy policy. The groups said that Google was in violation of the California Online Privacy Protection Act. As the groups explained, "California law requires the operator of a commercial web site to 'conspicuously post its privacy policy on its Web site." Google initially said that it would upset the web page aesthetic to include the word "privacy," but later made the modification. State of CA: AB 370 (Sept. 27, 2013) State of CA: SB 568 (Sept. 27, 2013) State of CA: SB 255 (Oct. 1, 2013) State of CA: CalOPPA EPIC: Online Tracking and Behavioral Advertising EPIC: Children's Online Privacy Privacy Rights: Letter to Google CEO Eric Schmidt (Jun. 2008) ========================================================================= [3] EPIC FOIA Docs Shed Light on Secret FBI Mobile Phone Tracking Team ========================================================================= In response to EPIC's Freedom of Information Act Lawsuit, the Federal Bureau of Investigation has released more than 400 pages of documents related to the cell site simulator technology commonly referred to as "StingRay." A StingRay is a device that can triangulate the source of a cellular signal by acting "like a fake cell phone tower" and measuring the signal strength of an identified device from several locations. With StingRays and other similar "cell site simulator" technologies, government investigators and private individuals can locate, interfere with, and even intercept communications from mobile phones and other wireless devices. The FBI's most recent release to EPIC is the latest in a series that began in 2012, and comprises over 4,000 pages of responsive documents. The most recent release includes training and promotional materials from the "Wireless Intercept & Tracking Team," a specialized unit within the FBI previously undisclosed to the public. According to the documents obtained by EPIC, the FBI's Tracking Team provides technical and financial support to a rapidly expanding group of federal and local law enforcement agents trained to use the controversial surveillance tools. The documents also reveal information about two other cellular surveillance technologies known as "Loggerhead" and "Triggerfish." While "Loggerhead" is largely obsolete, since it was used primarily to eavesdrop on older analog cell phones, "Triggerfish" is still apparently in use. The documents reveal that the FBI believes it can use cell site simulators without a warrant, but thus far only one federal court has considered the Fourth Amendment implications of these devices, including their interception of innocent users' data. Earlier in 2013, a federal court in Arizona permitted police to use evidence gathered by "StingRay" surveillance technology. The court held in United States v. Rigmaiden that investigators did not violate the Fourth Amendment. EPIC: Stingray/Cell Site Simulation EPIC: FBI's October 2013 Document Production EPIC: Complaint in EPIC v. FBI (Apr. 26, 2012) EPIC: EPIC v. FBI - Next Generation ID ========================================================================= [4] Court Rules that Gmail Case Can Go Forward ========================================================================= A federal district court has ruled that Google may have violated the federal Wiretap Act when it routinely intercepted, read, and acquired the contents of user email for advertising purposes. Judge Lucy Koh of the Northern District Court of California wrote, "The court finds that it cannot conclude that any party - Gmail users or non-Gmail users - has consented to Google's reading of e-mail for the purposes of creating user profiles or providing targeted advertising," The court rejected Google's arguments that the activity occurred in the "ordinary course of business." The court held that the interception must be "instrumental" to the provision of an email service and that Google's business interest was not sufficient to meet that test. The court also found that Google had not obtained consent from users for the company's ad profiling practices. According to the opinion, "Google has cited no case that stands for the proposition that users who send emails impliedly consent to interceptions and use of their communications by other . . . than the indented recipient of the email." The recent ruling applies also applies to Google Apps for Education, through which Google obtains emails from educational organizations of students, faculty, staff, and alumni. EPIC Appellate Advocacy Counsel Alan Butler was quoted in The New York Times, saying, "What's at stake is a core digital privacy issue for consumers right now, which is the extent to which their digital communications are protected from use by third parties." District Court of N. CA: Ruling in Google Wiretap Case (Sep. 26, 2013) EPIC: Gmail Privacy FAQ EPIC: Ben Joffe v. Google EPIC: Investigations of Google Street View ======================================================================== [5] EPIC Urges Congress on Student Privacy after Court Decision ======================================================================== In a letter to the US Senate and House Committees on Education, EPIC has asked Congress to restore privacy protections for student data. EPIC's letter follows a court opinion on recent changes to the Family Educational Rights and Privacy Act (FERPA), which held that neither EPIC nor any of EPIC's Board of Director co-plaintiffs "have standing to bring the claims asserted in the complaint." The judge did not address EPIC's substantive claims asserted in the complaint. EPIC's letter warned that the changes in the student privacy law allow the release of student records for non-academic purposes and undercut parental and student consent provisions, and urged Congress to investigate the impact of the revised regulations. "Students and families are losing control over sensitive information," EPIC wrote, "and private companies are becoming the repositories of student data and even the data maintained by the schools is far more extensive than ever before." EPIC's original lawsuit argued that the Education Department's changes to FERPA exceeded the agency's authority and that the revised regulations violate FERPA itself. Before initiating the lawsuit, EPIC submitted extensive comments to the Education Department, opposing the regulations. In comments, EPIC stated that the Education Department's recommendations "would undermine privacy safeguards set out in the [FERPA] statute and would unnecessarily expose students to new privacy risks." After the Education Department failed to modify the proposed regulations, EPIC filed suit in early 2012. "Through the FERPA's text, purpose, and legislative history, Congress unambiguously guaranteed students the right to prevent disclosure of directory information," EPIC stated. EPIC was joined in the lawsuit by EPIC Board of Directors members Grayson Barber, Pablo Garcia Molina, Peter Neumann, and Dr. Deborah Peel. EPIC has been a longtime advocate for student privacy rights. In 2011, EPIC filed a "friend of the court" brief in Chicago Tribune v. University of Illinois, a case involving student privacy rights protected by FERPA. Additionally, EPIC and more than 100 local, state, and national organizations previously urged then-Secretary of Defense Donald Rumsfeld to end the "Joint Advertising and Market Research Studies" Recruiting Database, which discloses personal information about 16-25-year-old Americans without obtaining individual consent. EPIC: Letter to Congress re: FERPA Decision (Oct. 9, 2013) EPIC: Court Order in EPIC v. Ed. Dept. (Sept. 26, 2013) EPIC: Memorandum Opinion in EPIC v. Ed. Dept. (Sept. 26, 2013) EPIC: Complaint in EPIC v. Ed. Dept. (Feb. 29, 2012) EPIC: Comments to Ed. Dept. on FERPA (May 23, 2011) EPIC: Brief in Chi. Tribune v. U. of Illinois (Jul. 20, 2011) Privacy Coalition: DoD Database Campaign Coalition Letter (2003) EPIC: EPIC v. The US Department of Education EPIC: Student Privacy ======================================================================== [6] News in Brief ======================================================================== NSA Attacked Tor, a Privacy Enhancing Network The NSA and Britain's GCHQ have attempted to break the privacy protections of the Tor anonymity network, according to a series of documents recently published in The Guardian. The documents describe the NSA's efforts to de-anonymize Tor users by using viruses to compromise their computers and the Tor software, and by following DoubleClick advertising cookies. The documents also reveal that despite the NSA's efforts the Intelligence Community has had limited success compromising the Tor network. One presentation, called "Tor Stinks," concludes that the IC will "never be able to de-anonymize all Tor users all the time." In May 2013, EPIC filed a FOIA request with the Broadcasting Board of Governors, seeking evidence of government interference with the Tor network. In 2000, EPIC filed a complaint with the FTC over DoubleClick's efforts to merge users' browsing activity with personally identifying information; in 2007, EPIC objected to Google's acquisition of DoubleClick, warning that it would place Internet users' privacy at risk. The Guardian: 'NSA and GCHQ target Tor network' (Oct. 4, 2013) network-encryption The Guardian: '"Tor Stinks" Project' (Oct. 4, 2013) stinks-nsa-presentation-document The Tor Project EPIC: FOIA Request to BBG re: Tor (May 31, 2013) EPIC: Complaint to FTC re: DoubleClick (Feb. 2000) EPIC: EPIC v. BBG - Tor EPIC: Privacy? Proposed Google/DoubleClick Merger EPIC FOIA: FBI Says 20% Error Rate Okay for Facial Recognition EPIC's Freedom of Information Act lawsuit against the FBI has produced new documents about "Next Generation Identification" and the FBI's plans for facial recognition systems. According to one of the documents obtained by EPIC, "NGI shall return an incorrect candidate a maximum of 20% of the time", a percentage much greater than expected. Earlier in 2013, EPIC received other documents from the FBI on the use of facial recognition and state DMV photos. The FBI still has not updated a 2008 Privacy Impact Assessment on facial recognition technology despite 2012 Congressional testimony that a new assessment was planned. EPIC: FOIA Complaint Against FBI re: Facial Recognition (Apr. 8, 2013) EPIC: EPIC v. FBI - Next Generation Identification EPIC: FOIA Docs from FBI on Facial Recognition (Oct. 2010) EPIC: FOIA Docs on Agreement Between FBI and State of IL (2012-2013) EPIC: FOIA Request to FBI on Facial Recognition Systems (Mar. 29, 2013) FBI: Testimony Before US Senate on Facial Recognition (Jul. 18, 2012) EPIC: Facial Recognition EPIC FOIA - New Information on Drone Flight Applicants The Federal Aviation Administration has responded to an EPIC FOIA request seeking documents related to applications to fly drones in US airspace by providing a list of nearly 200 entities within the Department of Defense, the Department of Homeland Security, the Department of Justice, and state and federal law enforcement agencies. The FAA further responded to EPIC's request for information by making the drone licenses, or "certificates," available on a public portal. EPIC has called on the FAA to maintain a searchable database of all drone operators as the agency seeks to expand domestic drone use. FAA: Response to EPIC FOIA Request on Drones (Sep. 24, 2013) EPIC: FOIA Request to FAA re: Drone Applications (Aug. 5, 2011) EPIC: List from FAA of Domestic Drone Applicants (Aug. 27, 2013) FAA: Drone Programs and Initiatives EPIC: Comments to FAA on Domestic Drone Use (Apr. 23, 2013) EPIC: Domestic Unmanned Aerial Vehicles (UAVs) and Drones EPIC Updates and Relaunches 'Practical Privacy Tools' EPIC has updated and expanded one of its most popular web pages of all time - "Practical Privacy Tools." EPIC's "Practical Privacy Tools" page includes a detailed listing of Internet Anonymizers, Proxy Servers, email encryption, secure Internet messaging, password vaults, antivirus programs, cookie cleaners, and more. Although EPIC does not endorse any particular product or service, EPIC strongly supports the widespread availability of privacy enhancing techniques. As EPIC explained to Congress in 1998, "techniques to protect privacy and anonymity should be encouraged and restrictions on encryption should be lifted." EPIC: Online Guide to Practical Privacy Tools EPIC: Testimony to Congress on Privacy Tools (Mar. 1998) Privacy Groups Ask Congress to End Secret Hearings on Data Industry EPIC, joined by a coalition of consumer privacy groups, has asked the US House of Representatives Privacy Task Force to open to the public meetings now taking place in secret on Capitol Hill. "We recognize that there is value in private meetings among Members and staff and with constituents," the group wrote, but added, "with public matters of common concern" meetings should be held "in the open, a public record should be created, and various viewpoints should be heard." The groups thanked Representatives Marsha Blackburn (R-TN) and Peter Welch (D-VT) for examining "the enormously important issue of consumer privacy" but said, "there is simply no reason for your task force to hold closed- door sessions." In 2012, both the White House and the Federal Trade Commission recommended enactment of consumer privacy legislation. EPIC et al.: Letter to Congressional Privacy Task Force (Oct. 1, 2013) FTC: 'Protecting Consumer Privacy in an Era of Rapid Change' (Mar. 2012) The White House: 'Consumer Data Privacy in a Networked World' (Feb. 2012) ======================================================================== [7] EPIC in the News ======================================================================== "Snapchat hack secretly saves images using app." BBC, Oct. 15, 2013. "Feds Demand Supreme Court Thwart Challenge to NSA Phone Spying." Wired, Oct. 15, 2013. "Facial Recognition Software That Returns Incorrect Results 20% Of The Time Is Good Enough For The FBI." Tech Dirt, Oct. 15, 2013. recognition-software-that-returns-incorrect-results-20-time-is- good-enough-fbi.shtml "FBI's Facial Recognition Software Could Fail 20 Percent of the Time." National Journal, Oct. 14, 2013. software-could-fail-20-percent-of-the-time-20131014?mrefid= LeadStoryTiles_medium "Yahoo to make SSL encryption the default for Webmail users. Finally." The Washington Post, Oct. 14, 2013. yahoo-to-make-ssl-encryption-the-default-for-webmail-users-finally/ "Administration looks to dodge Supreme Court challenge to NSA program." The Hill, Oct. 14, 2013. administration-looks-to-dodge-supreme-court-challenge-to-nsa- program "Amid NSA Outrage, Big Tech Companies Plan to Track You Even More Aggressively." Wired, Oct. 11, 2013. "FBI Files Reveal New Info on Clandestine Phone Surveillance Unit." Slate, Oct. 8, 2013. intercept_and_tracking_team_files_reveal_new_information_on.html "Why journalists can still trust Tor." Columbia Journalism Review, Oct. 8, 2013. "White House pursues online privacy bill amid NSA efforts." Politico, Oct. 7, 2013. bill-nsa-efforts-97897.html?hp=l10 "Church and state, executive power on Supreme Court docket." CNN, Oct. 6, 2013. "Deciding Who Sees Students' Data." The New York Times, Oct. 5, 2013. students-data.html?hp&_r=1& "Report: NSA tried, largely failed to crack Tor network." The Hill, Oct. 4, 2013. nsa-tried-largely-failed-to-crack-tor-network For More EPIC in the News: ======================================================================== [8] EPIC Bookstore ======================================================================== "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 laws. 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). Price: $98. 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 privacy law, including: identity theft, government data mining and electronic surveillance law, the Foreign Intelligence Surveillance Act, intelligence sharing, RFID tags, GPS, spyware, web bugs, and more. Information Privacy Law, Second Edition, builds a cohesive foundation 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 in over 75 countries around the world. The report outlines legal protections, new challenges, and important issues and events relating to privacy. 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). This reference guide provides the official UN documents, regional and issue-oriented perspectives, and recommendations and proposals for future action, as well as a useful list of resources and contacts for individuals and organizations that wish to become more involved in the WSIS process. ================================ "The Privacy Law Sourcebook 2004: United States Law, International Law, and Recent Developments," Marc Rotenberg, editor (EPIC 2005). Price: $40. The Privacy Law Sourcebook, which has been called the "Physician's Desk Reference" of the privacy world, is the leading resource for students, 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 Bookstore: ================================ 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: ======================================================================= [9] Upcoming Conferences and Events ======================================================================= Surveillance Conference, Sponsored by the Chicago Committee to Defend the Bill of Rights. Speaker: EPIC Domestic Surveillance Counsel Amie Stepanovich. Northwestern University School of Law, Evanston, IL, 19 October 2013. For More Information: American Civil Liberties Union of Rhode Island 2013 Annual Dinner Celebration. Keynote Speaker: EPIC Domestic Surveillance Counsel Amie Stepanovich. Providence, RI, 8 November 8, 2013. For More Information: ======================================================================= Join EPIC on Facebook and Twitter ======================================================================= Join the Electronic Privacy Information Center on Facebook and Twitter: Join us on Twitter for #privchat, Tuesdays, 11:00am ET. Start a discussion on privacy. Let us know your thoughts. Stay up to date with EPIC's events. Support EPIC. ======================================================================= Privacy Policy ======================================================================= The EPIC Alert mailing list is used only to mail the EPIC Alert and to send notices about EPIC activities. We do not sell, rent or share our mailing list. We also intend to challenge any subpoena or other legal process seeking access to our mailing list. We do not enhance (link to other databases) our mailing list or require your actual name. In the event you wish to subscribe or unsubscribe your e-mail address from this list, please follow the above instructions under "subscription information." ======================================================================= About EPIC ======================================================================= The Electronic Privacy Information Center is a public interest research center in Washington, DC. It was established in 1994 to focus public attention on emerging privacy issues such as the Clipper Chip, the Digital Telephony proposal, national ID cards, medical record privacy, and the collection and sale of personal information. EPIC publishes the EPIC Alert, pursues Freedom of Information Act litigation, and conducts policy research. For more information, see or write EPIC, 1718 Connecticut Ave. NW, Suite 200, Washington, DC 20009. +1 202 483 1140 (tel), +1 202 483 1248 (fax). ======================================================================= Donate to EPIC ======================================================================= If you'd like to support the work of the Electronic Privacy Information Center, contributions are welcome and fully tax-deductible. Checks should be made out to "EPIC" and sent to 1718 Connecticut Ave. NW, Suite 200, Washington, DC 20009. Or you can contribute online at: Your contributions will help support Freedom of Information Act and First Amendment litigation, strong and effective advocacy for the right of privacy and efforts to oppose government and private-sector infringement on constitutional values. Thank you for your support. ======================================================================= Subscription Information ======================================================================= Subscribe/unsubscribe via web interface: Back issues are available at: The EPIC Alert displays best in a fixed-width font, such as Courier. ------------------------- END EPIC Alert 20.20------------------------

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