House Bill 1909: Automatic License Plate Reader Systems

My testimony to the State of Washington House Transportation Committee:

Chair Clibborn and members of the committee, my name is Christopher Sheats, Chair of the Privacy Committee for Seattle’s Community Technology Advisory Board, and Chair of the Seattle Privacy Coalition. I want to make clear that any form of Automatic License Plate Reader (ALPR), regardless of its security or policy controls, is fundamentally a mass-surveillance system for the simple fact that it indiscriminately collects data about everyone.

ALPR mass-surveillance systems collect an incredible amount of personal information.

Where are you and where are you not?
Where are you heading?
What time were you there and not anywhere else?
Who else was traveling or not traveling around that time?

All of these personal facts can facilitate identifying our interests, affiliations, activities, and beliefs. Data collection, and any amount of data retention, allows for the copying and sharing of said data. According to the U.S. Department of Transportation Bureau of Transportation Statistics, an “overwhelming majority of person trips—for all purposes—are taken in personal vehicles.” When mass-surveillance data of our vehicles is collected, granularly surveilling a state, a city, a community, or an individual becomes trivial.

Where do they live?
Who lives around them?
Where do they go to church?
Who else goes to their church?
Where do they work?
When do they visit their friends and family?
When do they drop their children off at school or childcare?
When do they leave the house to go grocery shopping?
When do they visit their doctor and how often?

Answering these questions go above and beyond “personal information,” yet these questions become answerable when data collected by an ALRP mass-surveillance system is gathered by an abusive government or hacker, domestic or foreign.

If the State is to condone APRL mass-surveillance systems, whereby we have precluded we will not protect human rights by not collecting personal data in the first place, the only other rational alternative is to not retain collected data for any period longer than absolutely needed.

Thank you for your time.

Concerns of mine that I did not include in my testimony because of the delicate nature of politics:

Regarding House Bill 1909, I have several concerns:

1. How is House Bill 1909 going to impact RCW 40.24 — Address Confidentiality for Victims of Domestic Violence, Sexual Assault, and Stalking? Particularly, how is House Bill 1909 going to protect vulnerable people from law enforcement abuses?

2. Is any part of the ALPR mass-surveillance system, including data retention, managed or operated by unregulated third party providers?

3. Why are third parties not explicitly barred from owning and operating ALRP mass-surveillance systems?

4. What specific controls and audit safeguards will be put in place to prevent system operators from performing unapproved searches of people or vehicles?

5. Once data is collected by mass-surveillance systems, it can be copied, used, copied again, and re-used for unimaginable purposes. What specific controls and audit safeguards will be put in place to prevent data copying by federal agency data systems such as regional Fusion Centers?

6. The “Second War Powers Act of 1942” removed Census privacy protections of Japanese-Americans, allowing federal agents to know exactly where go and whom to arrest. How is Washington State going to defend us from unconstitutional policy changes brought on by an illegitimate U.S. President?

Advertisements