A Common Sense Approach to Location Data and Sensitive Places of Interest

June 21, 2022

By: Jason Sarfati, Chief Privacy Officer & VP Legal, Gravy Analytics

Following the recent news that the Supreme Court may overturn Roe v. Wade, there have been claims made by some lawmakers and journalists asserting that companies are selling the location data of devices that visit sensitive places, including most notably, abortion clinics. I understand these parties are simply searching for ways to protect the healthcare of U.S. citizens as one of the most significant rulings of our time hangs in the balance, but true progress will not be made by spreading misinformation about the mobility data industry.

At Gravy Analytics, we maintain a dynamic privacy blacklist layered over sensitive places of interest. This list naturally includes abortion clinics and other health care centers. It also includes other places where the most vulnerable members of our society tend to visit – such as schools, LGBT+ bars, and religious centers. While we cannot speak on behalf of every other company in the location data space, it has been our general observation that most have self-adopted this practice as a rule of business.

However, it appears the recent press coverage regarding this subject has resulted in a significant overcorrection. Today, many advocates and lawmakers are calling for a wholesale blackout of mobility data processing for these locations. This is wrong. As we have seen from recent headlines, important analytical and research work is currently being performed over these places. In many cases, this important analytics work is being performed by city-planners, non-profits, and real estate developers, meaning that they are not able to enjoy the public research exceptions that are currently being contemplated by a variety of federal and state privacy bills.          

Gravy Analytics wholly supports common sense regulation for data in regard to sensitive locations. However, the free flow of pseudonymous or anonymized data must be maintained for important research and analytical purposes. Fortunately, our dynamic privacy blacklist functions permit aggregate-level analysis over these places so we can understand them better without identifying the specific individuals who visit them. 

This purpose-based limitation is an absolute imperative. At the present time, policy makers and private industries are making important decisions about how best to improve and protect the communities we live in. Where should we place new schools and hospitals?  How has the relative distance traveled to hospitals, and even abortion clinics, changed over time?  Are there certain neighborhoods and communities that are suffering more than others? The answers to these questions can all be answered with the help of mobility data analytics.

We must continue this important work, and reject policy proposals that completely ban any processing over these locations. Doing so would only hurt the vulnerable communities and constituencies which we are seeking to protect. 

Jason Sarfati is available upon request to discuss trending issues around privacy and mobility data analytics.  Formal press requests can be sent to [email protected].

Gravy Analytics complies with all applicable local privacy laws, including California’s Consumer Privacy Act (“CCPA”) and the EU’s General Data Protection Regulation (“GDPR”). We allow anyone to request their information or to delete their data at any time. For more information, visit gravyanalytics.com/consumer-privacy.

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