Privacy issues for City Wi-Fi Deployments

At the end of last month, Seattle posted a request for information exploring the feasibility of a municipal Wireless deployment. With others at the Seattle Privacy Coalition, I draft a response to the city flagging some of the major privacy issues that we hope they will consider in the initiative. I believe these are much broader than just our specific case, and hopefully can help others when navigating the landscape of business models and privacy risks in this area.

Pitfalls of Public Wi-Fi: data selling, tracking of nonusers, injecting ads

Freely available municipal wireless Internet is an exciting service, but there have also been Wi-Fi deployments that have had significant, unintentional impacts on citizen privacy. This brief from the Seattle Privacy Coalition attempts to highlight some of the hidden costs that the City of Seattle should watch out for.

Many freely offered commercial wireless systems make money by selling analytics about customer behavior. An example is the Google-sponsored Wi-Fi provided at SeaTac airport and used in Starbuck’s coffee shops around town. While free to users, these services make money through the sale of user data to third-party advertisers.

This practice is especially questionable when low-income communities are targeted with ‘free’ services, greatly increasing the surveillance burden for an already vulnerable population.

Tracking and profiting from the sale of people’s behavior for advertising or other commercial purposes is a troubling practice at best, but it clearly goes against the public interest when it targets communities depending on a service as their primary or only access to the Internet.

Another threat to privacy found in commercial wireless deployments is the ability to track and analyze the behavior and location of every person in the vicinity, whether they are using the service or not. Cisco’s Meraki, a popular retail wireless product, advertises that it can “Glean analytics
from all Wi-Fi devices connected and unconnected.”

The city, perhaps unlike a business, has a responsibility to protect citizen privacy, and we think it would be irresponsible to track the locations of unconnected devices that have not explicitly opted-in to such a program.

From the start, the City must have a clear understanding of how collected data will be used, and it must not collect any data without the consent of the people tracked. Few citizens will welcome long-term, involuntary behavioral and location logging of their personal electronic devices by the government.

Finally, there are instances of wireless service which are based on a business model of injecting advertisements into web browsing. We merely note this is impossible to do without severely compromising the security of the Internet experience, and we do not believe that any trade off of benefits involving such approaches are justified.

We welcome additional digital connectivity through the city, and are especially excited by the potential for more equitable accessibility. There’s great potential in this technology, and while some incarnations impinge user privacy, many others have found successful models that avoid
such pitfalls.