Facial recognition - is it part of my digital footprint or not?



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US: The Federal Trade Commission has announced that it is seeking public comments on the privacy and security implications raised by the use of facial recognition technology, specifically seeking public comments on the following:
  • What are the current and future commercial uses of these technologies?
  • Comment : let’s immediately limit this to what we can understand or gather what the fear could be. This is the right question to get the wrong answer.  A better question would be, “which problem will facial recognition solve on its own?

  • How can consumers benefit from the use of these technologies?

    • Comment : Consumers only benefit if the eco-system or society benefit. Consumers don’t often seen benefit until after the policy.  Why let the animals run the zoo!

  • What are the privacy and security concerns surrounding the adoption of these technologies, and how do they vary depending on how the technologies are implemented?

    • Comment : fear, uncertainty and doubt. What concerns where there when photographic or CCTV equipment was developed, was there originally fear of electricity, telephones, plastics, radios, TV and the internet.  Why is the policy taking the stance “Let’s stop the ship now and get off as the sea may be less dangerous here to jump into than over there in a boat.”

  • Are there special considerations that should be given for the use of these technologies on or by populations that may be particularly vulnerable, such as children?

    • Comment : this makes an assumption about the application and who is running the service and assumes that data is collected, stored, associated and then used (abused) – Again the question should be focussed on what and where should regulation be applied and how should we be creating market dynamics that provide rights to those who need them. Let’s stop being focussed on collection and storage and focus on where the value is…. Grown up regulation !

  • What are best practices for providing consumers with notice and choice regarding the use of these technologies?

    • Comment : Assumption already implied in the questions is that the consumer does not see or gain any value from the exchange of their face being recognised.  Basic question – why do you need facial recognition and what are you trying to associate an image to.  Facial recognition has no value without being able to link it to some form of database…. Ahem – where should we focus !
    • So the announcement was put out by Amanda Koulousias – Google Images gives me her image, Radaris gives me some connections, Search engines give me CV, BIO, profile etc.  What step are we actually talking about here – is it the capture or the association, the right to hide, freedom or something else?

  • Are there situations where notice and choice are not necessary? By contrast, are there contexts or places where these technologies should not be deployed, even with notice and choice?

    • Comment : My heart says again wrong question as I cannot work out what the concern is…. Are you taking about capture of your image, storage of the image, analysis of the image, association of the image or creating value from the process?  The problem I would contend is not the service by the presentation of the data/ analysis back to the user. The same applies with location. Depending on how I (the service provider) feeds back the knowledge of location will either be creepy or value enhancing. Creepy services tend to die fast. Or are we concerned about Government tracking?

  • Is notice and choice the best framework for dealing with the privacy concerns surrounding these technologies, or would other solutions be a better fit? If so, what are they?

    • Comment : No

  • What are best practices for developing and deploying these technologies in a way that protects consumer privacy?

    • Comment : Big assumption and who made the judgement that your privacy trumps national security ?

    Workshop by FTC : http://www.ftc.gov/bcp/workshops/facefacts/

    Whilst this is an equally contentious issue in EU – especially in Germany, is facial recognition part of my digital footprint?