1. Vehicle Public Disclosure Laws
Efficiency vs. Privacy
In the interest of creating greater efficiency and reducing cost for both our internal
programs and for services offered by private companies, motor vehicle
Administrator we often encounter issues stemming from privacy requirements and
considerations in relation to the sharing of vehicle owner information.
Examples
include initiatives to allow rental companies to issue license plates, toll
collection to fund road infrastructure projects, and providing vehicle rental
companies with an automated driver license status checking tool. Hear what
jurisdictions are doing to address these issues. Bring your questions for an open
Dialogue.
Washington State
Vehicle Public Disclosure Laws

2. What exactly is a vehicle record?
What protects these records?
Who is allowed to obtain these records?
A vehicle record is a combination of information about a particular vehicle and all of the individuals and businesses that have an ownership interest in that vehicle. State motor vehicle agencies use these records in their vehicles and to fairly assess taxes and fees for their use on public roads. primarily to help protect our citizen’s ownership interest
Law enforcement agencies need access to the records for a wide variety of public safety and criminal investigation uses.
But there are also a lot of other government entities and private businesses that need access to our records to properly function: toll collectors, banks, insurance companies, lawyers, tow truck operators – the list goes on and on.
Under federal and state laws, parts of these records are generally protected, private information and other parts are not. However, even information that is private can or must be shared under the right circumstances.
Who is allowed to have them?
Our State law is generally permissive – a business that needs vehicle owner information to conduct their normal business functions qualifies.
Private citizens are only entitled to records for vehicles they have an ownership interest in.

3. Driver Privacy Protection Act
Section Prohibition on release and use of certain personal information from State
motor vehicle records
The DPPA covers the issues of privacy for both drivers and motor vehicles.
DPPA is very restrictive -- it spells out permitted uses and generally prohibits those who receive vehicle records from disclosing to others.
The DPPA is more restrictive than our state laws in WA in defining what legitimate purposes are that can be accepted.
Our state laws prohibit the release of personal information from vehicle records to the general public. They do however, have provisions for releasing info to business for legitimate business purposes. Under state law, these business purposes are not well defined, but they do exclude marketing or using the information to make sales calls.
The Driver Privacy Protection Act (18 U.S.C. § 2721 et. seq.) is different. IT allows the release of information under these circumstances:
the requestor is a government agency
For notifications related recalls or other public safety issues
To verify information provided to a business is accurate
for use related to a court case
For research or statistical analysis
For insurance underwriting
For vehicle impound notifications
For private investigators
For employers of commercial drivers
For tolling operations
For marketing uses when the vehicle owner has consented to the release of their own records
The DPPA also prohibits the re-release or reselling of information obtained for the above purposes. It includes criminal and civil penalties for violations. Section Prohibition on release and use of certain personal information from State
motor vehicle records
(a) In General -- Except as provided in subsection (b), a State department of motor vehicles, and any officer, employee, or contractor, thereof, shall not knowingly disclose or otherwise make available to any person or entity personal information about any individual obtained by the department in connection with a motor vehicle record.
(b) Permissible Uses -- Personal information referred to in subsection (a) shall be disclosed for use in connection with matters of motor vehicle or driver safety and theft, motor vehicle emissions, motor vehicle product alterations, recalls, or advisories, performance monitoring of motor vehicles and dealers by motor vehicle manufacturers, and removal of non-owner records from the original owner records of motor vehicle manufacturers to carry out the purposes of the Automobile Information Disclosure Act, the Motor Vehicle Information and CostSaving Act, the National Traffic and Motor Vehicle Safety Act of 1966, the Anti-Car Theft Act of1992, and the Clean Air Act, and may be disclosed as follows:
(1) For use by any government agency, including any court or law enforcement agency, in carrying out its functions, or any private person or entity acting on behalf of federal, State, or local agency in carrying out its functions.
(2) For use in connection with matters of motor vehicle or driver safety and theft; motor vehicle emissions; motor vehicle product alterations, recalls, or advisories; performance monitoring of motor vehicles, motor vehicle parts and dealers; motor vehicle market research activities, including survey research; and removal of non-owner records from the original owner records of motor vehicle manufacturers.

4. Unfortunately there is a common perception of the confidence many folks have of our ability to protect their information. As a consequence it is vital that we do all we can to safe guard this important information so that it can’t be utilize for inappropriate purposes.
“Relying on the government to protect your privacy is like asking a peeping tom to install your window blinds.”
 John Perry Barlow

5. Tracking Some public concerns include the possibility of tracking
Tracking –the idea that government can track their movement. Along with media reports about the locations of individuals being tracked by cell phones are reports about the use of automated vehicle identification systems based on license plates for tolling or law enforcement are becoming more common. These types of systems appear to make some members of the public uneasy and the use of these systems outside of the government could lead to even more anxiety.
Tracking

6. Marketing – concerns they will get telephone solicitors and junk mail
Marketing – concerns they will get telephone solicitors and junk mail. Unchecked, marketers could create highly valuable contact lists based on vehicle data. How much would a mailing list made up of individuals in particular areas who all own several expensive luxury cars be worth to a marketing firm?
Marketing

7. Criminal Activity – identity theft, vehicle fraud or theft, domestic violence. We all know that vehicles are valuable items and there are many types of crime surrounding them. Our data can be used to locate vehicles or their owners for illegal reasons or to produce legitimate-looking forged documents.
Criminal activity

8. We must lean heavily on doing what it takes to do it right.
Efficiency vs. Privacy.
We must lean heavily on doing what it takes to do it right.
So when it comes to Efficiency vs. Privacy. We must lean heavily on doing what it takes to do it right.

9. Efficiency vs. Privacy Gigi Zenk Communications Director, WA DOL
In the interest of creating greater efficiency and reducing cost for both our internal
programs and for services offered by private companies, motor vehicle
Administrator we often encounter issues stemming from privacy requirements and
considerations in relation to the sharing of vehicle owner information.
Examples
include initiatives to allow rental companies to issue license plates, toll
collection to fund road infrastructure projects, and providing vehicle rental
companies with an automated driver license status checking tool. Hear what
jurisdictions are doing to address these issues. Bring your questions for an open
Dialogue.
Gigi Zenk
Communications Director, WA DOL