In comments to the National Institutes of Health, an agency component of Health and Human Services, EPIC urged the agency to safeguard personally identifiable information following natural disasters. The agency proposes to use the PEOPLE LOCATOR system and related mobile app ReUnite™ to reunite "family and friends who are separated during a disaster." The PEOPLE LOCATOR system allows third parties to enter highly sensitive information about each missing or located individual, which in turn is accessed by the public. The system stores disaster survivor information including name, location, date of birth, race, religion, health status, address, and photographs. EPIC recommended that the agency: (1) limit its data collection to relevant information, (2) protect the security of the system by implementing data access control and establishing data quality standards; (3) define a record retention and disposal schedule; and (4) establish guidelines, which adhere to the Fair Information Practices, for disclosures to third parties like Google. For more information, see EPIC: Locational Privacy.
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Communications Law and Policy
Jerry Kang and Alan Butler