1. Privacy Rights of Individuals When They Request Help
11 Apr 2007
Washington DC
Privacy Rights of Individuals When They Request Help
Panel: Allison Mankin
John Morris
Alain Van Gaever
Tony Rutkowski
Tony Rutkowski
VP for Regulatory Affairs and Standards
VeriSign

2. Background
The FCC raised the possibility of “customer privacy protections related to provision of E911 service by interconnected VoIP service providers” in the FNPRM in Docket at para. 62, 3 Jun 2005
Proposal seemed limited to location information
Information will always be provided to public safety personnel
an emergency caller is presumed to consent to release of his location
Only CDT and NENA appear to have commented (Aug-Sep 2005) – focus is on location information
No FCC action to date
On a larger scale, FCC has assumed Title I jurisdiction over public Internet use in the U.S. and passed judicial muster

3. Privacy of Customer Information 47 U.S.C. § 222
(d) Exceptions
(4) to provide call location information concerning the user of a commercial mobile service
(A) to a public safety answering point, emergency medical service provider or emergency dispatch provider, public safety, fire service, or law enforcement official, or hospital emergency or trauma care facility, in order to respond to the user’s call for emergency services;
(B) to inform the user’s legal guardian or members of the user’s immediate family of the user’s location in an emergency situation that involves the risk of death or serious physical harm; or
(C) to providers of information or database management services solely for purposes of assisting in the delivery of emergency services in response to an emergency.
(g) Subscriber listed and unlisted information for emergency services
...a telecommunications carrier that provides telephone exchange service shall provide [subscribers’ telephone numbers, addresses] (including information pertaining to subscribers whose information is unlisted or unpublished) that is in its possession or control (including information pertaining to subscribers of other carriers) ... to providers of emergency services, and providers of emergency support services, solely for purposes of delivering or assisting in the delivery of emergency services.

4. Summary
Privacy norms for emergency request communications seem similar worldwide
In the U.S., privacy is generally grounded on
Expectations of privacy under the circumstances
“Right to be let alone”
Oriented around restraints on government action
Non-U.S. jurisdictions have explicit privacy exceptions
Traditional privacy norms suggest privacy is not an issue where emergency requests to public safety entities
Richer array of information for emergency requests can be provided with new user-centric Identity Management framework capabilities that bind privacy templates to broad array of personal and medical information
See ITU-T Focus Group on Identity Management
There is substantial synergy among rich information array use- cases (e.g., WARN Act EMS, law enforcement support requirements, healthcare services, etc)