FPF Comments on FTC and NHTSA Connected Vehicle Workshop

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Car with technology feature

On Monday, the Future of Privacy Forum submitted written comments to the Federal Trade Commission and the Department of Transportation, National Highway Traffic Safety Administration in response to their request for input on the benefits and privacy and security issues associated with current and future motor vehicles.

FPF commends the FTC and NHTSA for working together to host a public workshop focused on privacy and security issues related to connected vehicles. It is a valuable opportunity to expand the dialogue among regulators, industry, and advocates regarding expectations for consumer privacy in a rapidly evolving field.

As the automotive sector becomes more data-intensive, conversations of this kind are vital for fostering informed and constructive consumer protections. We look forward to participating in the workshop. Below, we highlight several items for consideration by the agencies and for the workshop.

FPF recommends that the FTC and NHTSA:

  1. highlight the importance of transparency and communication around consumer data use, including through the provision of clear user interfaces and resources that are: 1) publicly available; 2) accessible before purchase; 3) reviewable throughout the life of a vehicle; as well as the incorporation of consumer privacy controls when appropriate
  2. understand the importance of distinguishing between types of data in the vehicle context for any regulatory approaches to privacy (i.e. between data that is operationally critical or not, personally identifiable or not, sensitive or not), as well as the importance of accurately mapping data flows in a vehicle before apportioning responsibility between actors;
  3. encourage alignment between federal and state regulatory guidance and encourage industry self-regulatory efforts;
  4. consider the risks of connected vehicle data collection by state and local regulators, and propose guidance resources to support these regulators in data management best practices;
  5. monitor new entrants to the market that may seek to monetize connected vehicle data without fully understanding existing consumer protections; and
  6. recognize that this technological shift will have impacts beyond the automotive sector, particularly in the insurance and credit industries.

A cohosted workshop by NHTSA and the FTC is an important step in enabling advocates, industry, and consumers to build an understanding of the regulatory landscape of this rapidly evolving sector. We commend the agencies for working together, and we look forward to participating in the beginning of this dialogue around an emerging field.

Read the full comments here.

FPF’s extensive work in this area includes:

Our analyses are based on our own research, as well as interactions with members of industry, academics, advocates, and regulators.