Intrado Beware sm legality, Privacy and Use Considerations Ron Fournet

Ron Fournet

Intrado SAT Team Six Leader & Executive Advisor

Protecting the Community With Intrado Beware

Ronald.Fournet@intrado.com
Mobile 720.317.7593

January 9, 2017

Summary

Intrado Beware^SM complies with all the key laws of the US concerning “Personally Identifiable Information” (PII) as well as industry standards and best practices concerning privacy and the protection of PII. While US and state statutes allow public safety nearly un-restricted usage of PII data, Beware suppresses many data elements considered non-essential for the performance of the first responder mission, thus further ensuring the privacy of our citizens, their property and their associations.

The use of Beware is considered to be a “value-add” process overlaying and augmenting established protocols and procedures of public safety, not replacing them. Often Beware presents data unavailable to public safety, but which could prove highly instrumental in the successful resolution of 911 and emergency events. Cell phone numbers is such an example as they can be used to open communication channels with a hostage-taker, locate nearby relatives of a victim, etc.

Legality

Beware complies with all the key PII laws of the US, to include the following:

1965 Freedom of Information Act (FOIA)

1970 Fair Credit Reporting Act (FCRA)

1970 Bank Secrecy Act

1994 Drivers Privacy Protection Act (DPPA)

2000 Graham Leach Bliley Act (GLB)

2001 Patriot Act

2003 FACT Act

It is important to note that while Beware complies with these foundation laws, Beware actually performs on a higher threshold for privacy by suppressing non-essential PII data (e.g. redacting the SSN) and using scoring techniques to present actionable information without exposing private information at a ‘raw’ level.

The ACLU has long recognized the accepted use of PII in helping enforce the laws of the country and in protecting our communities. The caution has always been against any “unauthorized, arbitrary or capricious” use of PII data. To that end, providers of services that use PII must guard against unauthorized, arbitrary or capricious use of PII. With Beware, we have implemented a series of privacy processes to guard the PII of our citizens, including the credentialing of all our clients and end-users, strict information security environment provisions, continuous monitoring-of-usage processes, and compliance reviews on a scheduled basis. And with the use of redaction, suppression and scoring, we continue to seek the highest of privacy standards.

As stated before, the use of Beware is intended to be supplemental and augmentative to established first responder procedures and protocol. Beware presents a wealth of data helpful to the first responder in the performance of mission; but it is not to be used as the sole reference point in making life-saving decisions. The first responder must continue to rely on their training and experience.

The use of public and commercial records in public safety began in the mid-nineties, and has become an accepted and established practice. Criminal records serve as a good example of “best practice use”. Criminal records, a specific category of public records, will often reflect data in criminal justice information systems (CJIS). And while some officials may react to what they believe is “CJIS data”, it technically is not in that the criminal records were collected at the source (i.e., the county courthouse) by a commercial aggregator and then made available to other commercial providers (such as Intrado with Beware). And since this is usually on a national basis, the provisioning is with a ‘national view’. Said differently, a local first responder using Beware could see results on a person who lives in a far away state, and these results may indeed present a ‘more complete’ picture of the people involved in the emergency event.

And finally, Intrado provides initial and continuous training to public safety personnel in the use of Beware to ensure that use considerations will always be recognized and optimized.