Location services and privacy

Using geolocation in a trustworthy and compliant way

Simon.Hania@tomtom.com

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Trends that threaten trust

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Connected cars with downloadable appsLocation services, cloud, internet-of-thing, big data

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4. TomTom HD Traffic3. IQ Routes2. Map Share 1. Base maps

Revolutionising navigationIn 4 steps

4. TomTom HD Traffic3. IQ Routes2. Map Share 1. Base maps

4. TomTom HD Traffic3. IQ Routes2. Map Share 1. Base maps

4. TomTom HD Traffic3. IQ Routes2. Map Share 1. Base maps

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TomTom Traffic coverageIt covers up to 99.9% of all roads

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Creating TomTom HD Traffic: data sourcesRange of high-quality real-time data sources

TomToms trip archiveAnonymous location and speed information from the TomTom user community

5 billion (10E9) speed measurements per day5 trillion (10E12) speed measurements to date!by customers driving 50 billion kilometresand visiting every spot over 1,000 times

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Travel times to hospital

Based on real world measurements

LONDON

Based on theoretical maximum speeds

The reality check that can help to save lives

Origin/Destination analysis

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Example: Trips with Frankfurt Airport as destination

• Where are your customers coming from?

• What routes do they take?

• How may drivers are passing?

• Etc.

• Combine with other geo-based data sources for additional analysis

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Drivers, police & TomTomAn explosive mixture

Location privacy is top of mindWith bloggers, press, regulators, enforcers, legislators and many users alike

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• TomTom investigated by leading European Data Protection Authority in 2011

• TomTom’s use of location data is in accordance with EU Data Protection Laws

• Processing and delivery to third parties 100% OK

• Informing users needed to be more explicit, including opt-in

Community input – with permission

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We profile roads, not people

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How to enact?Nothing totally new, really

1. Principles - is what everyone should know

2. People - make the difference: good and bad

3. Policies - are like high level requirements

4. Projects - is where everything is put together

5. Processes - is what we use to stay predictable

6. Procedures - exist to avoid re-inventing wheels

7. Paperwork - document everything properlyalso used internally

TomTom & Privacy

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Vision:

Community input (crowd sourcing) is strategic

Privacy helps to realize business objectives by ensuring trust

Privacy is integral part of business continuity above and beyond legal compliance

Principles:

1. Avoid unpleasant surprises:

• Customer insight is paramount

• Be open and explain – hesitation is an omen

• Keep it simple

2. The customer remains in control of his personal data: we have it “on a loan”

also used internally

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Privacy Policies, Standards & Guidelines

7 key objectives

1. We asses our intended use of PD early to drive requirements

2. We document PD: purpose, legitimate ground, retention, access, jurisdiction(s)

3. We ensure we have obtained or will obtain informed user consent

4. We minimize the amount of PD (volume and time) and who has access: we de-personalize or destroy PD as soon as possible

5. We keep ensuring adequate security measures based on risk assessment of confidentiality, integrity and availability

6. We do not expose PD to any third party, unless the third party contractually agrees to comply to our policies (or law forces us)

7. We enable the user to exercise his rights (information, access/download, correction, deletion) also used

internally

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The 6 privacy questions

1. What personal data are we processing?

2. Why are we processing personal data?

3. When can we destroy the personal data?

4. Who will have access and will be accountable?

5. Where will we process and store the personal data?

6. Will we have a legitimate basis for processing?

also used internally

Privacy, amongst others, is about the protection of personal data

Personal data:

• Contains (whatever) information relating to a natural (“real”) person

• That person could be identified, directly or indirectly

• Typically: data attached to unique identifiers

Anonymous only:

• When no reasonable way exists to identify (“single out”) a person

• Even when requiring correlation with other data sources (e.g. maps and phonebooks)

• By anyone with the right resources

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also used internally

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Typical personal data misconceptionsvery often present in technology companies

• We do not identify the user while using the data, so we have no issues with privacy law

• We only use the serial number of the users device, so the data is anonymous and we have no issues with privacy law

• We encrypt the data, so we are no longer using/receiving/sending personal data

• We use hashes to replace all serial numbers, so the data is now anonymous and we have no issues with privacy law

• We anonimize the data, so we are not using personal data

• We can use the users’ data for anything we want, as long as we keep the data to ourselves

• Look: big name companies are doing the same, so we are OK also used

internally

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Can location data be anonymous?Research indicates: hardly ever

Avoiding re-identification is keyTomTom has a strict code of conduct to adhere to privacy laws

• Historic trip archive only to be used for road, traffic and related purposes

• No access to raw data outside TomTom, ever

• TomTom performs processing

• TomTom ensures re-identification is impossible e.g. through sufficient aggregation

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1 month

1 day

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Lessons learnt

• It is about trust and credibility, not about privacy or laws:

• “Anonymous”, “aggregated” is evasive terminology

• Data given in good faith, used against me

• Be prepared to explain and take action, even if that hurts

• Have your act together:

• Avoid squirrel behavior – data minimization is key

• Tell what you do with your users data and stick to it

• Be able to produce all relevant documentation very timely

• Co-operate with privacy regulators, don’t fight them

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Recommendations

• Incorporate data protection requirements from the start

• Take a multi-disciplinary approach: it is about your “license to operate in the information society”

• Embed “privacy by design” into development processes

• Document your data: “what, why, when, who, where”

• Consider law enforcement/e-discovery implications

• Appoint a “privacy czar” in your organization