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- HOUSE BILL NO. 367
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-IN THE LEGISLATURE OF THE STATE OF ALASKA
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-THIRTY-FOURTH LEGISLATURE - SECOND SESSION
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-BY REPRESENTATIVE STORY
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-Introduced: 2/23/26
-Referred: Judiciary, Finance
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-A BILL
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-FOR AN ACT ENTITLED
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-"An Act relating to the privacy of consumer personal information; establishing the 1
-Consumer Personal Information Privacy Act; establishing data broker registration 2
-requirements; relating to social security numbers; making certain violations unfair or 3
-deceptive trade practices; and providing for an effective date." 4
-BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF ALASKA: 5
- * Section 1. AS 44.33.020(a) is amended by adding a new paragraph to read: 6
-(45) establish and maintain a data broker registry established under 7
-AS 45.48.900. 8
- * Sec. 2. AS 45.48.430(b) is amended to read: 9
-(b) The prohibition in (a) of this section does not apply if 10
-(1) the disclosure is authorized by local, state, or federal law, including 11
-AS 45.48.800 - 45.48.945 or a regulation adopted under AS 45.48.470; 12
-(2) the person is engaging in the business of government and 13
-(A) is authorized by law to disclose the individual's social 14
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-security number; or 1
-(B) the disclosure of the individual's social security number is 2
-required for the performance of the person's duties or responsibilities as 3
-provided by law; 4
-(3) the disclosure is to a person subject to or for a transaction regulated 5
-by the Gramm-Leach-Bliley Financial Modernization Act, and the disclosure is for a 6
-purpose authorized by the Gramm-Leach-Bliley Financial Modernization Act or to 7
-facilitate a transaction of the individual; 8
-(4) the disclosure is to a person subject to or for a transaction regulated 9
-by the Fair Credit Reporting Act, and the disclosure is for a purpose authorized by the 10
-Fair Credit Reporting Act; 11
-(5) the disclosure is part of a report prepared by a consumer credit 12
-reporting agency in response to a request by a person and the person submits the social 13
-security number as part of the request to the consumer credit reporting agency for the 14
-preparation of the report; or 15
-(6) the disclosure is for a background check on the individual, identity 16
-verification, fraud prevention, medical treatment, law enforcement or other 17
-government purposes, or the individual's employment, including employment benefits. 18
- * Sec. 3. AS 45.48.450(b) is amended to read: 19
-(b) Notwithstanding the other provisions of AS 45.48.400 - 45.48.480, and 20
-except as provided under AS 45.48.800 - 45.48.945 or for an agent under (a) of this 21
-section, a person may disclose an individual's social security number to an 22
-independent contractor of the person to facilitate the purpose or transaction for which 23
-the individual initially provided the social security number to the person, but the 24
-independent contractor may not use the social security number for another purpose or 25
-make an unauthorized disclosure of the individual's personal information. In this 26
-subsection, "independent contractor" includes a debt collector. 27
- * Sec. 4. AS 45.48 is amended by adding new sections to read: 28
-Article 6A. Consumer Personal Information Privacy. 29
-Sec. 45.48.800. Notice before collection; disclosure of information; other 30
-notices. (a) A business that collects personal information from a consumer shall notify 31
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-the consumer before collecting the information. Notification to the consumer must 1
-clearly and conspicuously indicate the categories of personal information that will be 2
-collected, the specific purposes for which each category of personal information will 3
-be used, the consumer's right under AS 45.48.835 not to have the consumer's personal 4
-information sold, shared, or disclosed, and the limitations established under 5
-AS 45.48.840 on the use of the consumer's precise geolocation data by the business. A 6
-business may not collect an additional category of personal information or use the 7
-collected personal information for an additional purpose without first notifying the 8
-consumer in accordance with this section. 9
-(b) A business shall maintain, and update at least once every 12 months, in the 10
-business's online privacy policies and in any state-specific description of consumers' 11
-privacy rights, or on the business's Internet website if the business does not maintain 12
-online privacy policies or description, the following information: 13
-(1) a description of a consumer's rights under AS 45.48.800 - 14
-45.48.945; 15
-(2) all the designated methods of the business by which a consumer 16
-can request access to or deletion of information as provided under AS 45.48.800 - 17
-45.48.945; 18
-(3) a list of the categories of consumer personal information that the 19
-business collected, sold, or disclosed for a business or commercial purpose in the 20
-preceding 12 months, and a designation of that information as collected, sold, or 21
-disclosed for a business or commercial purpose; or, if the business did not collect, sell, 22
-or disclose any consumer personal information for a business or commercial purpose, 23
-a disclosure of that fact; 24
-(4) the categories of sources from which the consumer personal 25
-information was collected; in this paragraph, "categories of sources" includes the 26
-consumer, advertising networks, Internet service providers, data analytics providers, 27
-government entities, operating systems and platforms, social networks, data brokers, 28
-other sources listed in regulations adopted under AS 45.48.800 - 45.48.945, and other 29
-types or groupings of persons or entities from which a business collects personal 30
-information about consumers, described with enough particularity to provide 31
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-consumers with a meaningful understanding of the type of person or entity; 1
-(5) a description of the business purpose or commercial purpose for 2
-which each category of consumer personal information was collected, sold, or 3
-disclosed; 4
-(6) the categories of third parties to whom the business sold or 5
-disclosed consumer personal information; in this paragraph, "categories of third 6
-parties" includes advertising networks, Internet service providers, data analytics 7
-providers, government entities, operating systems and platforms, social networks, data 8
-brokers, other sources listed in regulations adopted under AS 45.48.800 - 45.48.945, 9
-and other types or groupings of third parties with whom the business shares personal 10
-information, described with enough particularity to provide consumers with a 11
-meaningful understanding of the type of third party; 12
-(7) a description of a consumer's right to request the specific pieces of 13
-the consumer's personal information that the business collected; 14
-(8) a statement that information collected to verify a consumer's 15
-disclosure or deletion request shall only be used as provided in AS 45.48.850(d) and 16
-(e)(1). 17
-(c) In addition to the requirements under (b) of this section, a business shall 18
-include on the home page of the business's Internet website under the business's online 19
-privacy policies, if the business has online privacy policies, and under any state-20
-specific description of consumers' privacy rights, the following: 21
-(1) a clear and conspicuous link to an Internet website page titled "Do 22
-Not Collect or Sell My Personal Information" that enables a consumer to exercise the 23
-consumer's rights under AS 45.48.800 - 45.48.945; a business may not require a 24
-consumer to create an account to access this Internet website page or to exercise the 25
-consumer's rights under AS 45.48.800 - 45.48.945; and 26
-(2) a description of a consumer's rights under AS 45.48.800 - 27
-45.48.945. 28
-(d) A business may comply with (c) of this section by including the required 29
-content on a separate and additional Internet website page that is dedicated to 30
-consumers. 31
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-(e) A business shall include on an Internet website page dedicated to 1
-consumers the content required under (b) and (c) of this section and reasonably ensure 2
-that consumers are directed to the alternative Internet website. 3
-(f) In this section, "home page" means 4
-(1) the introductory page of an Internet website where personal 5
-information is collected; 6
-(2) in the case of a mobile application, the application's platform page 7
-or download page, an electronic link within the application, and any other location that 8
-allows consumers to review the notice required by (a) of this section. 9
-Sec. 45.48.805. Limits on use, processing, collection, sharing, and retention 10
-of personal information. (a) A business that collects a consumer's personal 11
-information shall limit its collection and sharing of the personal information with third 12
-parties to what is reasonably necessary for the business to provide a service or conduct 13
-an activity that a consumer has requested, or has consented to, or that is reasonably 14
-necessary for security or fraud prevention. In this subsection, "reasonably necessary 15
-for security or fraud prevention" does not include profiting financially from the 16
-personal information. 17
-(b) A business that collects a consumer's personal information is not required 18
-to retain personal information collected for a single one-time transaction if the 19
-business does not sell or disclose the information. 20
-(c) Except for the collection and sharing of personal information under (a) of 21
-this section, a business shall limit the business's use and retention of collected personal 22
-information to what is reasonably necessary to provide a service or conduct an activity 23
-that a consumer has requested or consented to, or for a related operational purpose; 24
-however, personal information that is collected or retained solely for security or fraud 25
-prevention may not be used for operational purposes. 26
-Sec. 45.48.810. Notification of business upon receipt or disclosure of 27
-personal information. (a) When a person receives personal information for a business 28
-purpose or commercial purpose that a business originally collected from a consumer, 29
-the person shall notify the business that the person possesses the personal information 30
-and provide the person's contact information. The person shall provide updated contact 31
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-information to the business if the person's contact information changes. 1
-(b) A person who receives personal information that a business originally 2
-collected from a consumer, and who discloses the personal information to another 3
-person for a business purpose or commercial purpose, shall notify the business that 4
-originally collected the information not later than 10 days after the disclosure. The 5
-notification must include the contact information of the person to whom the personal 6
-information was disclosed. 7
-(c) A person that receives personal information that a business originally 8
-collected from a consumer shall either de-identify the personal information or 9
-maintain the personal information in a way that the person can readily comply with a 10
-disclosure or deletion request under AS 45.48.800 - 45.48.945. 11
-Sec. 45.48.815. Required records. A business that collects or has collected 12
-personal information from a consumer shall maintain records of each person to whom 13
-the business discloses the personal information. The business shall also maintain all 14
-records provided to the business under AS 45.48.810(a) and (b). 15
-Sec. 45.48.820. Request for disclosure of collected personal information. 16
-(a) A consumer may request a business that collects or collected the consumer's 17
-personal information to disclose to the consumer 18
-(1) the categories and specific pieces of personal information that the 19
-business collects or collected within the five years preceding the date of the request; 20
-(2) the sources from which the business collects or collected each 21
-category of personal information; and 22
-(3) the business purpose or commercial purpose for the collection of 23
-each category of personal information. 24
-(b) A business shall respond to a consumer request under this section as 25
-required by AS 45.48.850. 26
-Sec. 45.48.825. Request for deletion of personal information. (a) A 27
-consumer may request a business to delete any of the consumer's personal information 28
-collected by the business from the consumer within the five years preceding the date 29
-of the request. 30
-(b) Upon receiving a consumer request under this section, a business shall 31
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-delete from the business's records the information identified in the request. 1
-(c) Within 45 days after a consumer's deletion request, a business that receives 2
-a deletion request under (b) of this section shall direct all persons to whom a business 3
-disclosed records under AS 45.48.810 to delete the personal information and provide a 4
-written statement verifying that the information has been deleted. A person shall 5
-comply with a direction under this subsection. The business shall immediately provide 6
-written notification to the attorney general and the consumer of a person who fails to 7
-provide written verification of compliance. 8
-(d) A person is not required to delete personal information under (c) of this 9
-section if the person maintains the personal information to 10
-(1) complete the transaction for which the personal information was 11
-collected; 12
-(2) provide a good or service requested or reasonably anticipated 13
-within an ongoing business relationship with the consumer; 14
-(3) fulfill the terms of a written warranty or product recall conducted in 15
-accordance with federal law; 16
-(4) perform a contract between the business and consumer; 17
-(5) detect security incidents, protect against malicious, deceptive, 18
-fraudulent, or illegal activity, or prosecute the person responsible for that activity; 19
-(6) identify and repair errors that impair the existing intended 20
-functionality of a product or service; 21
-(7) exercise a right provided for by law, including the right under the 22
-First Amendment of the United States Constitution and art. I, sec. 5, of the 23
-Constitution of the State of Alaska to freedom of speech, or ensure the right of another 24
-consumer to exercise that consumer's right to freedom of speech; 25
-(8) comply with a search warrant, subpoena, or court order; 26
-(9) engage in public or peer-reviewed scientific, historical, or 27
-statistical research in the public interest that adheres to all other applicable ethics and 28
-privacy laws, if 29
-(A) the deletion of information is likely to seriously impair or 30
-render impossible the achievement of the research; and 31
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-(B) the consumer has provided consent to the research; 1
-(10) enable solely internal uses that are reasonably aligned with the 2
-consumer's expectations, based on the consumer's relationship with the business; or 3
-(11) comply with a legal obligation. 4
-(e) A person may not disclose personal information that a business collected 5
-from a consumer unless the personal information is disclosed in accordance with a 6
-contract that requires the recipient to comply with a deletion request issued under 7
-AS 45.48.800 - 45.48.945. 8
-Sec. 45.48.830. Request for disclosure of personal information sold or 9
-disclosed for a business purpose or commercial purpose. (a) A consumer may 10
-request that a business that sold or disclosed the consumer's personal information for a 11
-business purpose or commercial purpose within the last five years disclose to the 12
-consumer 13
-(1) the third parties subject to AS 45.48.810 in possession of the 14
-consumer's personal information; 15
-(2) the categories of personal information or specific pieces of personal 16
-information that were sold or disclosed to each third party for a business purpose or 17
-commercial purpose; 18
-(3) for the third parties to which the business directly disclosed the 19
-consumer's personal information for a business purpose or commercial purpose, the 20
-business purpose or commercial purpose for disclosing each category of personal 21
-information. 22
-(b) A business shall respond to a consumer request under this section as 23
-required by AS 45.48.850. 24
-Sec. 45.48.835. Request not to sell, share, or disclose personal information. 25
-(a) A consumer may, at any time, request a business not to sell, share, or disclose the 26
-consumer's personal information or not to sell, share, or disclose particular categories 27
-of the consumer's personal information. 28
-(b) If a business collects personal information from a consumer online and the 29
-consumer uses a global privacy control, the business shall treat the use of the global 30
-privacy control as a valid request submitted by the consumer under (a) of this section 31
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-not to sell, share, or disclose the consumer's personal information. In this subsection, 1
-(1) "extension" means a piece of software code that enables a 2
-computer application or program to perform an activity the application or program 3
-cannot do by itself; 4
-(2) "global privacy control" includes a browser extension, privacy 5
-setting, device setting, or other mechanism that communicates or signals the 6
-consumer's choice not to have the consumer's personal information sold, shared, or 7
-disclosed. 8
-(c) A consumer may, as provided by regulation adopted under AS 45.48.915, 9
-authorize another person solely to request that a business not sell, share, or disclose 10
-the consumer's personal information, and a business shall comply with the request 11
-received from the person for the consumer. 12
-(d) A business shall respond to a consumer request under this section as 13
-required by AS 45.48.850, unless the consumer later provides a clear and explicit 14
-renunciation of the request. For one year after receiving a request under (a) - (c) of this 15
-section, a business may not contact the consumer to request that the consumer 16
-renounce the request. 17
-(e) A business subject to this section may only use the personal information 18
-collected from a consumer request under this section to comply with the request, 19
-unless otherwise authorized by the consumer or by another provision of law. 20
-Sec. 45.48.840. Use and disclosure of precise geolocation data. (a) A 21
-business may use a consumer's precise geolocation data for other purposes than the 22
-purpose disclosed under AS 45.48.800(a) if the consumer consents to the use. A 23
-consumer who consents to the use of the consumer's precise geolocation data for other 24
-purposes may, at any time, request that the business stop using the data for other 25
-purposes. The consumer's consent must be in writing and in an agreement separate 26
-from any other agreement for use, and the consumer must agree to the business's use 27
-of the consumer's precise geolocation data for other purposes. 28
-(b) Except as provided in (a) of this section, a business shall limit the use and 29
-disclosure of a consumer's precise geolocation data to that necessary to provide goods 30
-or services that a consumer requests and reasonably expects, or goods and services the 31
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-business reasonably expects the consumer will request. 1
-(c) The provisions of AS 45.48.800 - 45.48.945 do not apply to a business that 2
-uses a consumer's precise geolocation data if the consumer is an employee, contractor, 3
-or vendor of the business. 4
-Sec. 45.48.845. Treatment of individuals 16 years of age or under. (a) 5
-Notwithstanding any other provision of AS 45.48.800 - 45.48.945, a business that has 6
-actual knowledge that a consumer is 16 years of age or under may not 7
-(1) disclose the personal information of the consumer for a business 8
-purpose or commercial purpose, or use the consumer's precise geolocation data for a 9
-purpose other than to provide goods or services that the consumer reasonably requests 10
-and expects, unless the consumer's parent or guardian consents to the disclosure or 11
-use; or 12
-(2) sell or share the personal information of the consumer. 13
-(b) A business that recklessly disregards a reasonable likelihood that a 14
-consumer is 16 years of age or under is considered to have actual knowledge of the 15
-consumer's age. In this subsection, "recklessly" has the meaning given in 16
-AS 11.81.900(a). 17
-(c) A business may not track or profile the personal information of an 18
-individual who is 16 years of age or under in order to provide to the individual a 19
-commercial advertisement that is based on the personal information or online activity 20
-of the individual. 21
-Sec. 45.48.850. Disclosure or deletion request; process. (a) A business shall 22
-respond to a consumer request under AS 45.48.820 or 45.48.830 by 23
-(1) providing the requested information electronically to the consumer 24
-in a portable and, to the extent technically feasible, readily useable format that allows 25
-the consumer to transmit the information to another person without hindrance; 26
-(2) if the information provided under (1) of this subsection is not in a 27
-human-readable format, providing the requested information to the consumer in a 28
-format that is easily readable by a human; and 29
-(3) at the consumer's request, providing the requested information by 30
-mail. 31
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-(b) A business subject to AS 45.48.800 - 45.48.945 shall designate at least two 1
-methods for a consumer to submit a request under AS 45.48.820 - 45.48.835, 2
-including, at a minimum, a toll-free telephone number and an electronic mail address. 3
-If a business maintains an Internet website, the website must include an option to 4
-submit requests under AS 45.48.820 - 45.48.835 on a public facing page. A designated 5
-method for submitting requests may include a mailing address, electronic mail 6
-address, Internet website, Internet website portal, toll-free telephone number, other 7
-applicable contact information, or a new consumer-friendly means of contacting a 8
-business as determined by regulation. 9
-(c) A person may not charge a consumer a fee for performing a duty required 10
-by AS 45.48.800 - 45.48.945. 11
-(d) A person may only use the information provided by a consumer in a 12
-request made under AS 45.48.820 - 45.48.835 to identify the consumer and comply 13
-with the request. 14
-(e) In response to a request made under AS 45.48.820 - 45.48.835, a business 15
-shall 16
-(1) promptly determine whether the request is a consumer request; a 17
-business may not require that a consumer create an account with the business; 18
-however, if the consumer maintains an account with the business, the business may 19
-require the consumer to submit the request through the account; 20
-(2) identify in writing the personal information subject to a disclosure 21
-request; the information disclosed must 22
-(A) cover the 12-month period preceding the request, or 23
-another applicable period designated by the consumer; 24
-(B) be designated by the most relevant category of personal 25
-information; 26
-(C) clearly separate information requested under AS 45.48.820 27
-and 45.48.830; 28
-(3) disclose and deliver the identified information in writing not later 29
-than 45 days after receipt of the request; 30
-(4) not later than 45 days after receipt of a deletion request, comply 31
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-with AS 45.48.825, and provide confirmation of compliance to the consumer. 1
-(f) The time to respond to a disclosure or deletion request under (e)(3) and (4) 2
-of this section may be extended once for an additional 45 days when reasonably 3
-necessary. If the time to respond is extended, the business shall notify the consumer of 4
-the extension. 5
-(g) A business may disclose or provide confirmation of deletion of 6
-information to the consumer by mail, through the consumer's account with the 7
-business, or electronically at the consumer's request if the consumer does not have an 8
-account with the business. 9
-(h) Notwithstanding any other requirement in this section, if a consumer's 10
-requests are manifestly unfounded or excessive, in particular because of the requests' 11
-repetitive character, a business may either charge a reasonable fee, taking into account 12
-the administrative costs of complying with the consumer's request, or refuse to act on 13
-the request. The business shall notify the consumer of a decision to charge a fee or to 14
-deny a request within the timeline provided under (e)(3) and (4) and (f) of this section. 15
-The notification must completely explain the business's reason for finding the request 16
-manifestly unfounded or excessive, including all pertinent facts. The business shall 17
-bear the burden of proving that a consumer's request is manifestly unfounded or 18
-excessive. 19
-(i) A business is not required to respond to a disclosure or deletion request 20
-under AS 45.48.825 or 45.48.830 if the consumer making the request has made two 21
-consumer requests in the previous 365 days. 22
-(j) A business is not required under this section to re-identify or otherwise link 23
-data that, in the ordinary course of business, is not maintained in a manner that would 24
-be considered personal information. 25
-Sec. 45.48.855. Third-party disclosure and handling of personal 26
-information. (a) A third party may not disclose personal information to another 27
-person if the personal information was originally collected in violation of 28
-AS 45.48.800 or 45.48.835. A third party that reasonably inquires into whether 29
-personal information was collected in violation of AS 45.48.800 or 45.48.835, and 30
-reasonably concludes that information was not obtained in violation of AS 45.48.800 31
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-or 45.48.835 may not be held liable for a violation under this section. 1
-(b) A third party may not disclose a consumer's personal information for a 2
-business purpose or commercial purpose unless the third party receives written 3
-confirmation from the business that originally collected the personal information that 4
-the information was collected in compliance with AS 45.48.800 and 45.48.835. 5
-Sec. 45.48.860. Service provider obligations. (a) A service provider may not 6
-(1) retain, use, or disclose personal information received from a 7
-business for any purpose other than to perform the services specified in a written 8
-contract with the business; 9
-(2) combine personal information received from a business with 10
-personal information the service provider receives from other sources, unless 11
-otherwise provided in regulation; 12
-(3) disclose personal information received from a business to any other 13
-person without first 14
-(A) receiving written consent of the business to disclose the 15
-personal information to the other person; and 16
-(B) entering into a written contract with the other person that 17
-prohibits the other person from engaging in conduct prohibited under this 18
-section. 19
-(b) A person who receives personal information from a service provider may 20
-not disclose the personal information to any other person. 21
-Sec. 45.48.865. Exemptions. (a) AS 45.48.800 - 45.48.945 do not apply to 22
-(1) protected health information that is collected by a covered entity or 23
-business associate governed by the privacy, security, and breach notification rules 24
-issued by the United States Department of Health and Human Services in 45 C.F.R. 25
-Parts 160 and 164, established under the Health Insurance Portability and 26
-Accountability Act of 1996 (P.L. 104-191) and the Health Information Technology for 27
-Economic and Clinical Health Act (P.L. 111-5); in this paragraph, "protected health 28
-information" has the meaning given in 45 C.F.R. 160.103; 29
-(2) a covered entity governed by the privacy, security, and breach 30
-notification rules issued by the United States Department of Health and Human 31
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-Services in 45 C.F.R. Parts 160 and 164, established under the Health Insurance 1
-Portability and Accountability Act of 1996 (P.L. 104-191), to the extent the provider 2
-or covered entity maintains patient information in the same manner as medical 3
-information or protected health information as described in (1) of this subsection; 4
-(3) information collected as part of a clinical trial subject to 45 C.F.R. 5
-Part 46 (Protection of Human Subjects) under 6
-(A) good clinical practice guidelines issued by the International 7
-Council for Harmonisation of Technical Requirements for Pharmaceuticals for 8
-Human Use; or 9
-(B) human subject protection requirements of the United States 10
-Food and Drug Administration; 11
-(4) vehicle information or ownership information retained or shared 12
-between a new motor vehicle dealer, as defined in AS 45.25.990, and the motor 13
-vehicle manufacturer, as defined in AS 45.25.990, if the information is shared for the 14
-purpose of or in anticipation of effectuating a vehicle repair covered by a vehicle 15
-warranty or recall conducted under 49 U.S.C. 30118 - 30120, if the new motor vehicle 16
-dealer or vehicle manufacturer does not sell, share, or use the information for another 17
-purpose; in this paragraph, 18
-(A) "ownership information" means the name of each 19
-registered owner and accompanying contact information; 20
-(B) "vehicle information" means the vehicle identification 21
-number, the vehicle's make, model, or year, or the vehicle's odometer reading; 22
-(5) a person, including a subsidiary or affiliate of the person, and data 23
-that are subject to 15 U.S.C. 6801 - 6827 (Gramm-Leach-Bliley Act) and related 24
-regulations; 25
-(6) an individual's personal information collected by a business if the 26
-business collects the personal information through the individual's 27
-(A) job application made to the business; 28
-(B) service as an employee, officer, or director of the business; 29
-or 30
-(C) work as a contractor for the business and consists only of 31
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-(i) personal information used solely within the context 1
-for which it was collected; 2
-(ii) emergency contact information used solely for the 3
-purpose of having an emergency contact on file; or 4
-(iii) personal information retained solely to administer 5
-benefits for the individual. 6
-(b) AS 45.48.800 - 45.48.945 do not apply to the disclosure of a consumer's 7
-personal information to 8
-(1) comply with federal, state, or local law; 9
-(2) comply with a civil, criminal, or regulatory inquiry or an 10
-investigation, subpoena, or summons by federal, state, or local authorities; 11
-(3) cooperate with law enforcement agencies concerning conduct or 12
-activity that the person reasonably and in good faith believes may violate federal, 13
-state, or local law; 14
-(4) exercise or defend legal claims; 15
-(5) collect, use, retain, sell, or disclose de-identified consumer personal 16
-information or aggregated consumer personal information. 17
-(c) AS 45.48.800 - 45.48.945 do not apply to the collection or sale of a 18
-consumer's personal information if the commercial conduct takes place wholly outside 19
-the state. For the purpose of this subsection, commercial conduct takes place wholly 20
-outside the state if 21
-(1) the business collected the information while the consumer was 22
-outside the state; the exemption allowed under this subsection does not include the 23
-storage of personal information, including on a personal device, while the consumer is 24
-in the state and collection when the consumer and stored information later leave the 25
-state; 26
-(2) no part of the sale of the consumer's personal information occurred 27
-in the state; and 28
-(3) no personal information collected while the consumer was in the 29
-state was sold. 30
-(d) AS 45.48.800 - 45.48.875 and 45.48.885 - 45.48.945 do not apply to 31
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-(1) an activity that is subject to 15 U.S.C. 1681 - 1681x (Fair Credit 1
-Reporting Act) that involves the collection, maintenance, disclosure, sale, 2
-communication, or use of any personal information bearing on a consumer's 3
-creditworthiness, credit standing, credit capacity, character, general reputation, 4
-personal characteristics, or mode of living by a consumer reporting agency; 5
-(2) a furnisher of information who provides information for use in a 6
-consumer report, or a user of a consumer report, to the extent the information is used 7
-as authorized under 15 U.S.C. 1681 - 1681x (Fair Credit Reporting Act); 8
-(3) personal information collected, processed, sold, or disclosed under 9
-18 U.S.C. 2721 - 2725 (Driver's Privacy Protection Act of 1994) and related 10
-regulations. 11
-(e) Except as provided in AS 45.48.835 and 45.48.880, personal information 12
-contained in a written communication, oral communication, or transaction between a 13
-business and a consumer is exempt from AS 45.48.800 - 45.48.945 if 14
-(1) the consumer is an individual acting as an employee, owner, 15
-director, officer, member, or contractor of a sole proprietorship, partnership, limited 16
-liability company, corporation, association, or other legal entity that is organized or 17
-operated for the profit or financial benefit of its shareholders, partners, members, or 18
-other owners, or is a government agency; in this paragraph, "owner" means an 19
-individual who 20
-(A) owns, directly or indirectly, or has the power to vote, more 21
-than 50 percent of the outstanding shares of a class of voting securities of a 22
-business; 23
-(B) controls, in any manner, the election of a majority of the 24
-directors or of individuals exercising similar functions; or 25
-(C) has the power to exercise a controlling influence over the 26
-majority of the directors or of individuals exercising similar functions; and 27
-(2) the communication or transaction occurs solely within the context 28
-of the business exercising due diligence regarding a product or service of, the receipt 29
-of a product or service from, or providing a product or service to the corporation, 30
-partnership, sole proprietorship, or government agency. 31
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-(f) A requirement under AS 45.48.800 - 45.48.945 does not apply if 1
-(1) compliance with the requirement would violate an evidentiary 2
-privilege under state law; 3
-(2) the business provides personal information as part of privileged 4
-communication to a person covered by an evidentiary privilege; 5
-(3) the right or obligation would adversely affect a right of another 6
-consumer; 7
-(4) the requirement would infringe on the noncommercial activity of a 8
-person or entity exercising rights under art. I, sec. 5, Constitution of the State of 9
-Alaska. 10
-(g) A business does not sell or share a consumer's personal information under 11
-AS 45.48.800 - 45.48.945 if 12
-(1) the consumer intentionally directs the business to disclose the 13
-consumer's personal information to a third party, intentionally uses the business to 14
-disclose the consumer's personal information to a third party, or intentionally directs 15
-the business to interact with a third party, and the third party does not also disclose the 16
-personal information or discloses the personal information consistent with 17
-AS 45.48.800 - 45.48.945; 18
-(2) the business uses or shares a unique identifier for a consumer to 19
-alert third parties that the consumer has requested under AS 45.48.835 that the 20
-business not sell, share, or disclose the consumer's personal information or particular 21
-categories of the consumer's personal information. 22
-(h) A business does not sell personal information under AS 45.48.800 - 23
-45.48.945 when the business uses or shares with a service provider a consumer's 24
-personal information that is necessary to perform a business purpose if 25
-(1) the business has provided notice under AS 45.48.800 of the 26
-personal information being used or shared; and 27
-(2) the service provider does not further collect, sell, or use the 28
-consumer's personal information except as necessary to perform the business purpose. 29
-(i) In this section, 30
-(1) "contractor" means a person who is not an employee of a business 31
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-but provides a service to the business under a written contract; 1
-(2) "covered entity" has the meaning given in 45 C.F.R. 160.103; 2
-(3) "director" has the meaning given in AS 10.06.990; 3
-(4) "intentionally" does not mean hovering over, muting, pausing, or 4
-closing a piece of content; 5
-(5) "officer" means a person appointed or designated as an officer of a 6
-corporation by or under applicable law or the corporation's articles of incorporation or 7
-bylaws, or a person who performs for the corporation the functions usually performed 8
-by an officer of a corporation. 9
-Sec. 45.48.870. Retaliation prohibited; financial incentives. (a) A business 10
-may not retaliate against a consumer in response to a consumer exercising rights under 11
-AS 45.48.800 - 45.48.945. Retaliation includes 12
-(1) denying goods or services; 13
-(2) charging different prices or rates for goods or services, including 14
-using discounts or other benefits or imposing penalties; 15
-(3) providing a different level or quality of goods or services to a 16
-consumer; 17
-(4) suggesting that a consumer will receive a different price or rate for 18
-goods or services or a different level or quality of goods or services. 19
-(b) Notwithstanding (a) of this section, a business may charge a consumer a 20
-different rate or provide a different level or quality of goods or services to a consumer 21
-if the difference is reasonably related to the value provided to the business by the 22
-consumer's personal information. 23
-(c) Notwithstanding (a) of this section, a business may offer a consumer a 24
-financial incentive for the collection, sale, or retention of personal information, 25
-including direct payments to a consumer as compensation. A business that offers a 26
-financial incentive under this subsection 27
-(1) shall notify consumers of the financial incentive; 28
-(2) shall obtain a consumer's consent before entering a consumer into a 29
-financial incentive program; to obtain a consumer's consent under this paragraph, the 30
-business shall provide the consumer access to a clear and conspicuous description of 31
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-the material terms of the financial incentive program; the consumer may revoke the 1
-consent at any time; 2
-(3) may not use financial incentive practices that are unjust, 3
-unreasonable, coercive, or usurious. 4
-(d) In this section, "business" does not include a newspaper. 5
-Sec. 45.48.875. Transfer of information in a merger, acquisition, 6
-bankruptcy, and certain other transactions. (a) A business may transfer to or share 7
-with a third party a consumer's personal information as an asset that is part of a 8
-business change transaction. 9
-(b) If a business shares a consumer's personal information with a third party in 10
-the process of evaluating and consummating a business change transaction, the 11
-business shall require that the third party agree by contract to keep the personal 12
-information confidential and not use the personal information for a purpose other than 13
-evaluating and consummating the transaction. 14
-(c) A third party under (a) of this section may not use or share the consumer's 15
-personal information in a manner that is materially inconsistent with (a) of this section 16
-or with the uses identified in the notification made under AS 45.48.800. 17
-(d) A transfer under (a) of this section does not authorize a business to make 18
-material retroactive privacy policy changes or other changes in a manner that 19
-constitutes an unfair or deceptive trade practice under AS 45.50.471 - 45.50.561. 20
-(e) In this section, "business change transaction" means a merger, acquisition, 21
-bankruptcy, or other transaction in which the third party assumes control of all or part 22
-of the business. 23
-Sec. 45.48.880. Duty to maintain reasonable security measures. A business 24
-that owns, licenses, or maintains a consumer's personal information shall implement 25
-and maintain reasonable security procedures and practices appropriate to the nature of 26
-the information to protect the personal information from unauthorized access, 27
-destruction, use, modification, or disclosure. 28
-Sec. 45.48.885. Component parts. If a series of steps or transactions are 29
-component parts of a single transaction and are intended from the beginning to avoid 30
-the reach of AS 45.48.800 - 45.48.945, including a business's disclosure of 31
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-information to a third party to avoid being considered a sale, the steps or transactions 1
-may not be considered separate for the purposes of determining compliance with, an 2
-exception to, or a violation of AS 45.48.800 - 45.48.945. 3
-Sec. 45.48.890. Violations. (a) A violation of AS 45.48.800 - 45.48.945 is an 4
-unfair or deceptive act or practice under AS 45.50.471 - 45.50.561. Each day of a 5
-violation constitutes a separate violation. 6
-(b) In an action brought under AS 45.50.531(a), a consumer whose personal 7
-information is subjected to unauthorized access, destruction, use, modification, or 8
-disclosure has suffered an ascertainable loss of $1 or another amount proven at trial, 9
-whichever is greater. 10
-(c) The remedies under this section are in addition to the remedies provided 11
-under AS 45.48.080 for a violation of AS 45.48.010 - 45.48.090. 12
-Sec. 45.48.895. Consumer privacy account. (a) The consumer privacy 13
-account is established as a separate account in the general fund. 14
-(b) The consumer privacy account consists of 15
-(1) money appropriated to the account by the legislature; 16
-(2) the registration fees collected under AS 45.48.900(b)(2); 17
-(3) the fees collected under AS 45.48.910; and 18
-(4) civil penalties and money collected in or as a result of an action 19
-brought by the attorney general under AS 45.48.800 - 45.48.945. 20
-(c) The purposes of the consumer privacy account are to pay 21
-(1) the salaries of attorneys in the Department of Law that enforce the 22
-provisions of AS 45.48.800 - 45.48.945 at an amount that is competitive with the 23
-private sector; and 24
-(2) the administrative costs incurred by the department and the 25
-Department of Law to enforce AS 45.48.800 - 45.48.945. 26
-(d) The legislature may appropriate money deposited under (b)(2) - (4) of this 27
-section for the purposes of the account. 28
-Sec. 45.48.900. Data broker registration. (a) Before a business begins 29
-operating as a data broker, the business shall register with the commissioner in 30
-accordance with this section. 31
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-(b) To register as a data broker, a business shall 1
-(1) provide, on a form provided by the commissioner, 2
-(A) the name of the data broker; 3
-(B) the data broker's primary physical and mailing addresses; 4
-(C) the data broker's electronic mailing address; 5
-(D) the data broker's primary Internet website address; and 6
-(E) the data broker's "Do Not Collect or Sell My Personal 7
-Information" Internet website page as required under AS 45.48.800(c) or 8
-alternative Internet website page that meets the requirements of 9
-AS 45.48.800(d); and 10
-(2) pay a registration fee in an amount established by the department 11
-by regulation. 12
-(c) The department shall deposit the fees paid under (b)(2) of this section into 13
-the consumer privacy account established under AS 45.48.895. 14
-Sec. 45.48.905. Data broker registry publicly displayed. The commissioner 15
-shall make the information provided by data brokers under AS 45.48.900(b)(1) 16
-available on the department's Internet website. 17
-Sec. 45.48.910. Revenue fees. (a) A business that collects, sells, or shares 18
-personal information from a consumer shall pay a fee to the department. The amount 19
-of this fee is three percent of the revenue received by the business from the buying, 20
-selling, or sharing of the personal information of a consumer or household 21
-information. 22
-(b) The department shall deposit the fees paid under (a) of this section into the 23
-consumer privacy account established under AS 45.48.895. 24
-Sec. 45.48.915. Regulations. (a) The attorney general shall adopt regulations 25
-under AS 44.62 (Administrative Procedure Act) that 26
-(1) create specific exceptions required to comply with state or federal 27
-law; 28
-(2) govern the Internet website page requirement of AS 45.48.800, 29
-including 30
-(A) the use of a recognizable and uniform mark to identify the 31
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-opportunity to exercise a right under AS 45.48.800 - 45.48.945; 1
-(B) the submission of a consumer request; 2
-(C) a business's compliance with a request under AS 45.48.835; 3
-(3) update, as necessary, additional categories of personal information 4
-required to be disclosed in response to relevant changes in technology, data collection 5
-practices, privacy concerns, or obstacles to implementation; 6
-(4) update, as necessary, the interpretation of unique identifiers in 7
-response to relevant changes in technology, data collection practices, privacy 8
-concerns, or obstacles to implementation; 9
-(5) update, as necessary, the interpretation of designated methods for 10
-submitting requests to facilitate a consumer's ability to obtain information from a 11
-business; 12
-(6) establish requirements to ensure that notices and information 13
-provided under AS 45.48.800 are in plain language, accessible to consumers with 14
-disabilities, and available in the language primarily used by the business to interact 15
-with the consumer, including with regard to financial incentive offerings; 16
-(7) designate the process for a consumer to authorize a representative 17
-to exercise the rights provided under AS 45.48.800 - 45.48.945 on the consumer's 18
-behalf; and 19
-(8) further define the meaning of "profile." 20
-(b) The attorney general may adopt regulations under AS 44.62 21
-(Administrative Procedure Act) that 22
-(1) establish rules and procedures for processing and complying with a 23
-consumer request for specific pieces of personal information relating to a household to 24
-address obstacles to implementation and privacy concerns; 25
-(2) state that service providers may combine personal information for 26
-specified purposes; 27
-(3) are necessary to further the purposes of AS 45.48.800 - 45.48.945. 28
-(c) The department shall establish by regulation adopted under AS 44.62 29
-(Administrative Procedure Act) the amount of the registration fee that a data broker 30
-shall pay under AS 45.48.900(b)(2). 31
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-Sec. 45.48.920. Persons who may consent. Except as provided in 1
-AS 45.48.845(a), a person may provide consent for a consumer under AS 45.48.800 - 2
-45.48.945 if the person is 3
-(1) the consumer; 4
-(2) the consumer's legal guardian; 5
-(3) a person who holds a power of attorney for the consumer; or 6
-(4) a person who is acting as a conservator for the consumer. 7
-Sec. 45.48.925. Personnel training. A business subject to AS 45.48.800 - 8
-45.48.945 shall provide training to individuals responsible for handling consumer 9
-questions or requests under AS 45.48.800 - 45.48.945, including training the 10
-individuals how to direct a consumer to exercise the consumer's rights under 11
-AS 45.48.800 - 45.48.945. 12
-Sec. 45.48.930. Provisions not waivable. A consumer's waiver of the 13
-provisions of AS 45.48.800 - 45.48.945 is contrary to public policy and is 14
-unenforceable and void. This section does not prevent a consumer from 15
-(1) declining to request information from a business; 16
-(2) declining to request that a business not collect, sell, or disclose the 17
-consumer's personal information; or 18
-(3) authorizing a business to sell the consumer's personal information 19
-after previously requesting that the business not sell the personal information. 20
-Sec. 45.48.935. Liberal construction. The intent of AS 45.48.800 - 45.48.945 21
-is remedial and its provisions shall be liberally construed. 22
-Sec. 45.48.940. Definitions. In AS 45.48.800 - 45.48.945, unless the context 23
-indicates otherwise, 24
-(1) "aggregated consumer information" means information that relates 25
-to a group or category of consumers from which individual consumer identities have 26
-been removed, and that is not linked or reasonably linkable by a device or other 27
-method to a consumer or household; "aggregated consumer information" does not 28
-mean an individual consumer record that has been de-identified; 29
-(2) "application" means a computer software package that performs a 30
-specific function; 31
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-(3) "beacon" means a small computer device that allows computer 1
-information to be transmitted to a portable device that can connect to the Internet; 2
-(4) "business" means a sole proprietorship, partnership, limited 3
-liability company, corporation, association, or other legal entity that is organized or 4
-operated for the profit or financial benefit of its shareholders, partners, members, or 5
-other owners, that collects or has collected consumers' personal information or on the 6
-behalf of which that information is collected, that alone or jointly with others 7
-determines the purposes and means of processing personal information of consumers, 8
-that does business in the state, and that 9
-(A) satisfies one or both of the following thresholds: 10
-(i) alone or in combination with another person, 11
-annually buys, sells, or shares the personal information of 100,000 or 12
-more consumers or households; or 13
-(ii) derives 50 percent or more of its annual revenue 14
-from selling or sharing the personal information of consumers; or 15
-(B) controls or is controlled by a business that meets a 16
-threshold in (A) of this paragraph and shares a name, service mark, trademark, 17
-or other form of common branding with the business; in this subparagraph, 18
-"control" means 19
-(i) ownership or the power to vote more than 50 percent 20
-of the outstanding shares of any class of voting security of a business; 21
-(ii) control, in any manner, of the election of a majority 22
-of the directors or of individuals exercising similar functions; or 23
-(iii) the power to exercise a controlling influence over 24
-the majority of the directors or of individuals exercising similar 25
-functions; 26
-(5) "business purpose" means a use for an operational purpose or other 27
-notified purpose, if the use is reasonably necessary and proportionate to achieving the 28
-operational purpose or other notified purpose for which personal information was 29
-collected or processed, or is a compatible use; 30
-(6) "categories of personal information" includes a category of 31
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-personal information set out in (24) of this section and a category of personal 1
-information not specifically enumerated; 2
-(7) "collect" includes buying, renting, gathering, obtaining, receiving, 3
-or accessing personal information pertaining to a consumer by actively or passively 4
-receiving information from the consumer, by observing the consumer's behavior, or by 5
-any other means; 6
-(8) "commercial purpose" includes marketing, advertising, and any 7
-other purpose that advances a person's commercial or economic interests, except 8
-engaging in political speech, journalism, or other speech that state or federal courts 9
-have recognized as noncommercial speech; 10
-(9) "commissioner" means the commissioner of commerce, 11
-community, and economic development; 12
-(10) "compatible use" means 13
-(A) auditing related to a current interaction with the consumer 14
-and counting the advertisement impressions made to individual visitors, 15
-verifying positioning and quality of advertisement impressions, and auditing 16
-compliance with this paragraph, other standards, and other concurrent 17
-transactions; 18
-(B) detecting security incidents, protecting against malicious, 19
-deceptive, fraudulent, or illegal activity, and prosecuting those persons 20
-responsible for that activity; 21
-(C) identifying and removing errors from computer hardware 22
-or software that impair existing intended functionality; 23
-(D) the contextual customization of advertisements shown as 24
-part of the same interaction and other short-term transient use, if the personal 25
-information is not disclosed to a third party and is not used to build a profile 26
-about a consumer or alter the experience of an individual consumer outside the 27
-current interaction; 28
-(E) maintaining or servicing accounts, providing customer 29
-service, processing or fulfilling orders and transactions, verifying customer 30
-information, processing payments, providing financing, providing advertising 31
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-or marketing services, providing analytical services, and performing other 1
-services on behalf of the business or service provider; 2
-(F) conducting internal research for technological development 3
-and demonstration; 4
-(G) performing activities to verify or maintain the quality or 5
-safety of a service or device that is owned by, manufactured by, manufactured 6
-for, or controlled by the business, and to improve, upgrade, or enhance the 7
-service or device; or 8
-(H) performing another use that is consistent with the context 9
-in which the personal information was collected; 10
-(11) "consent" 11
-(A) means a consumer's freely given, specific, informed, and 12
-unambiguous indication by statement, action, or other method, that the 13
-consumer agrees to the processing of the consumer's personal information for a 14
-narrowly defined purpose; 15
-(B) does not mean 16
-(i) acceptance of general terms of use, a broad statement 17
-of terms of use, or a similar document that contains descriptions of 18
-personal information processing along with other, unrelated 19
-information; 20
-(ii) hovering over, muting, pausing, or closing a given 21
-piece of content on the Internet; or 22
-(iii) an agreement obtained through the use of a user 23
-interface designed or manipulated to subvert or impair user autonomy, 24
-decision making, or choice; 25
-(12) "conservator" has the meaning given in AS 13.06.050; 26
-(13) "consumer" means an individual who is a resident of the state 27
-under AS 01.10.055, whether identified by a unique identifier or other method of 28
-identification, but does not mean an individual acting 29
-(A) as an employee, owner, director, officer, member, or 30
-contractor or in another capacity of a corporation, limited liability company, 31
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-sole proprietorship, partnership, association, nonprofit, or other entity or 1
-government agency; 2
-(B) for the entity or agency with another entity or agency; or 3
-(C) in an employment context; 4
-(14) "consumer request" means a request that is made by a consumer, 5
-by a parent or legal guardian with legal custody of the consumer, or by a individual or 6
-a person registered with the United States Secretary of State, authorized by the 7
-consumer to act on the consumer's behalf; 8
-(15) "data broker" means a business that knowingly collects and sells 9
-to third parties the personal information of a consumer with whom the business does 10
-not have a direct relationship, but does not include a consumer reporting agency to the 11
-extent the agency is covered by 15 U.S.C. 1681 et seq. (Fair Credit Reporting Act); 12
-(16) "de-identified" means that the information cannot reasonably 13
-identify, relate to, describe, be capable of being associated with, or be directly or 14
-indirectly linked to, an individual consumer, and the business holding the information 15
-(A) has implemented technical safeguards that prohibit re-16
-identification of the consumer to whom the information may pertain; 17
-(B) has implemented business processes that specifically 18
-prohibit re-identification of the information; 19
-(C) has implemented business processes to prevent inadvertent 20
-release of de-identified information; and 21
-(D) makes no attempt to re-identify the information; 22
-(17) "department" means the Department of Commerce, Community, 23
-and Economic Development; 24
-(18) "device" includes a computer and a physical object that can 25
-(A) read, write, or store information that is represented in 26
-numerical form; 27
-(B) connect to the Internet, directly or indirectly, or to another 28
-device; 29
-(19) "disclose" includes all types of disclosure, including the 30
-disclosure of personal information related to a sale of personal information; 31
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-(20) "Internet website page" means a document accessible through the 1
-Internet with a unique identifier used to locate a resource on the Internet; 2
-(21) "knowingly" has the meaning given in AS 11.81.900(a); 3
-(22) "operational purpose" means the use of personal information, 4
-when reasonably necessary and proportionate, to achieve, if the use is limited to a 5
-direct relationship and experience with a consumer, 6
-(A) debugging to identify and repair errors that impair existing 7
-intended functions; 8
-(B) based on information collected by the business, 9
-undertaking internal research for analysis, product improvement, and 10
-technology development; 11
-(C) verification or maintenance of the quality or safety of a 12
-service or device that is owned, manufactured, manufactured for, or controlled 13
-by the business, or to improve, upgrade, or enhance a service or device that is 14
-owned, manufactured, manufactured for, or controlled by the business; 15
-(D) customization of content based on information collected by 16
-the business; or 17
-(E) customization of advertising or marketing based on 18
-information collected by the business; 19
-(23) "person" means an individual, proprietorship, corporation, 20
-company, partnership, firm, association, and any other nongovernmental organization 21
-or group of persons acting in concert; 22
-(24) "personal information" 23
-(A) means the information in the following categories that 24
-identifies, relates to, describes, is reasonably capable of being associated with, 25
-or could reasonably be linked, directly or indirectly, with a particular consumer 26
-or household: 27
-(i) a real name, alias, postal address, unique identifier, 28
-online identifier, Internet protocol address, electronic mail address, 29
-account name, or other identifier; 30
-(ii) signature; 31
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-(iii) physical characteristics or physical description; 1
-(iv) telephone number; 2
-(v) insurance policy number; 3
-(vi) characteristics of protected classifications under 4
-state or federal law; 5
-(vii) commercial information, including bank accounts, 6
-records of personal property, products or services purchased, obtained, 7
-or considered, or other purchasing or consuming histories or 8
-tendencies; 9
-(viii) browsing history, search history, and information 10
-regarding a consumer's interaction with an Internet website, 11
-application, or advertisement, or other Internet or electronic network 12
-activity information; 13
-(ix) geolocation data, including precise geolocation 14
-data; 15
-(x) audio, electronic, visual, thermal, olfactory, or 16
-similar information; 17
-(xi) professional or employment-related information; 18
-(xii) information that is personally identifiable 19
-information, as defined in 34 C.F.R. 99.3, that is not publicly available; 20
-(xiii) sensitive personal information; 21
-(xiv) inferences drawn from any of the information 22
-identified in this subparagraph to create a profile about a consumer 23
-reflecting the consumer's preferences, characteristics, psychological 24
-trends, predispositions, behavior, attitudes, intelligence, abilities, and 25
-aptitudes; 26
-(B) does not mean 27
-(i) publicly available information; 28
-(ii) consumer information that is de-identified or is 29
-aggregated consumer information; 30
-(iii) biometric information; in this sub-subparagraph, 31
- 34-LS1485\N
-HB 367 -30- HB0367a
- New Text Underlined [DELETED TEXT BRACKETED]
-
-"biometric information" means an individual's physiological, 1
-biological, or behavioral characteristics that can be used to establish 2
-individual identity; 3
-(25) "precise geolocation data" 4
-(A) means data that is derived from a consumer device through 5
-a technology that 6
-(i) is capable of determining with specificity the latitude 7
-and longitude coordinates or other spatial location of a person or 8
-device; 9
-(ii) has an accuracy level of less than 1,750 feet; 10
-(iii) uses a global positioning system, a triangulated 11
-location provided by a beacon, network radios, or a technology that 12
-allows computers, mobile phones, or other devices to connect to the 13
-Internet or communicate with one another wirelessly within a particular 14
-area, or another technology; 15
-(B) does not mean information that is or will be 16
-(i) altered before the information is processed, in order 17
-to be able to determine with specificity the physical location of an 18
-individual or device; 19
-(ii) used by a business when acting as an employer; 20
-(26) "processing" means any operation or set of operations performed 21
-on personal data or on sets of personal data, whether or not by automated means; 22
-(27) "profile" or "profiling" means automated processing of personal 23
-information, as further defined by regulation adopted under AS 45.48.915, to analyze 24
-or predict an individual's work performance, economic situation, health, personal 25
-preferences, interests, reliability, behavior, location, movements, or other personal 26
-features; 27
-(28) "publicly available information" means information that is 28
-lawfully made available from federal, state, or local government records, that a 29
-business has a reasonable basis to believe is lawfully made available to the general 30
-public by the consumer or from widely distributed media, or that a consumer makes 31
- 34-LS1485\N
-HB0367a -31- HB 367
- New Text Underlined [DELETED TEXT BRACKETED]
-
-available by a person to whom the consumer has disclosed the information if the 1
-consumer has not restricted the information to a specific audience; 2
-(29) "research" means scientific systematic study and observation that 3
-is in the public interest, that adheres to all applicable ethics and privacy laws, and 4
-(A) is compatible with the business purpose for which the 5
-personal information was collected; 6
-(B) is used solely for research purposes that are compatible 7
-with the context in which the personal information was collected; 8
-(C) is not used for a commercial purpose; and 9
-(D) in which the personal information is 10
-(i) later pseudonymized and de-identified, or de-11
-identified and in the aggregate, if the information cannot reasonably 12
-identify, relate to, describe, be capable of being associated with, or be 13
-linked, directly or indirectly, to a particular consumer; personal 14
-information is considered pseudonymized if the information is 15
-processed so that it is no longer attributable to a specific consumer 16
-without the use of additional information, and the additional 17
-information is kept separate and is subject to technical and 18
-organizational measures to ensure that the personal information is not 19
-attributed to an identified or identifiable consumer; 20
-(ii) subject to technical safeguards that prohibit re-21
-identification of the consumer to whom the information may pertain; 22
-(iii) subject to business processes that specifically 23
-prohibit re-identification of the information; 24
-(iv) subject to business processes to prevent inadvertent 25
-release of de-identified information; and 26
-(v) subjected by the business conducting the research to 27
-additional security controls that limit access to the research data to 28
-individuals in the business as necessary to carry out the research 29
-purpose; 30
-(30) "sale," "sell," or "sold" means renting, releasing, disclosing, 31
- 34-LS1485\N
-HB 367 -32- HB0367a
- New Text Underlined [DELETED TEXT BRACKETED]
-
-disseminating, making available, transferring, or otherwise communicating orally, in 1
-writing, or by electronic or other means, a consumer's personal information by a 2
-business to a third party for monetary or other valuable consideration or for another 3
-commercial purpose; 4
-(31) "sensitive personal information" means information that is not 5
-publicly available information and reveals 6
-(A) a consumer's social security number, driver's license 7
-number, known traveler number, state identification card number, passport 8
-number, or other unique identification number issued on a government 9
-document commonly used to verify the identity of a specific individual; 10
-(B) the number of a consumer's Internet account, financial 11
-account, debit card account, credit card account, or other account, in 12
-combination with any required security or access code, password, or 13
-credentials allowing access to the account; 14
-(C) a consumer's precise geolocation; 15
-(D) a consumer's racial or ethnic origin, religious or 16
-philosophical beliefs, mental or physical health diagnosis, sexual orientation, 17
-citizenship or immigration status, or union membership; 18
-(E) the contents of a consumer's mail or electronic mail, text 19
-message, or other electronic communication, unless the business possessing the 20
-information is the intended recipient of the communication; 21
-(F) a consumer's genetic data; 22
-(G) information about an individual who is less than 18 years 23
-of age; 24
-(H) information collected and analyzed concerning a 25
-consumer's health; or 26
-(I) information collected and analyzed about a consumer's 27
-sexual life or sexual orientation; 28
-(32) "service provider" means a person that receives personal 29
-information from a business to be used solely for a business purpose under a written 30
-contract that requires the service provider to comply with AS 45.48.860; 31
- 34-LS1485\N
-HB0367a -33- HB 367
- New Text Underlined [DELETED TEXT BRACKETED]
-
-(33) "share" means renting, releasing, disclosing, disseminating, 1
-making available, transferring, or otherwise communicating orally, in writing, or by 2
-electronic or other means personal information by a business to a third party for 3
-cross‐context behavioral advertising, whether for monetary or other valuable 4
-consideration, or in a transaction between a business and a third party for 5
-cross‐context behavioral advertising for the benefit of a business in which no money is 6
-exchanged; in this paragraph, "cross-context behavioral advertising" means the 7
-targeting of advertising to a consumer based on the consumer's personal information 8
-obtained from the consumer's activity across businesses, distinctly branded Internet 9
-websites, applications, or services, other than the business, distinctly branded website, 10
-application, or service with which the consumer intentionally interacts; 11
-(34) "third party" means any person, except 12
-(A) the business that collected the personal information from 13
-the consumer; and 14
-(B) a service provider contracting with the business that 15
-collected the personal information from the consumer; 16
-(35) "unique identifier" includes a device identifier; an Internet 17
-protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar 18
-technology; customer number, unique pseudonym, or user alias; telephone numbers, or 19
-other forms of persistent or probabilistic identifiers that can be used to identify a 20
-particular consumer or device; or another persistent identifier that can be used to 21
-recognize a consumer, a household, or a device that is linked to a consumer or 22
-household, over time and across different services; in this paragraph, 23
-(A) "cookie" means information from an Internet website 24
-stored by a person's computer that is used to identify the person's computer 25
-while the person is using the website; 26
-(B) "pixel tag" means a small design or picture that is loaded 27
-when a computer user visits an Internet website page or opens electronic mail; 28
-(C) "probabilistic identifier" means the identification of a 29
-consumer or a device to a degree of certainty of more probable than not based 30
-on a category of personal information included in, or similar to, the categories 31
- 34-LS1485\N
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-
-of personal information. 1
-Sec. 45.48.945. Short title. AS 45.48.800 - 45.48.945 may be cited as the 2
-Consumer Personal Information Privacy Act. 3
- * Sec. 5. AS 45.50.471(b) is amended by adding a new paragraph to read: 4
-(58) violating AS 45.48.800 - 45.48.945 (Consumer Personal 5
-Information Privacy Act). 6
- * Sec. 6. The uncodified law of the State of Alaska is amended by adding a new section to 7
-read: 8
-APPLICABILITY: CONTRACTS. This Act applies to a contract entered into on or 9
-after the effective date of secs. 1 - 6 of this Act. 10
- * Sec. 7. The uncodified law of the State of Alaska is amended by adding a new section to 11
-read: 12
-TRANSITION: REGULATIONS. The attorney general shall adopt regulations as 13
-authorized under AS 45.48.915, added by sec. 4 of this Act, to implement the changes made 14
-by this Act. The regulations take effect under AS 44.62 (Administrative Procedure Act), but 15
-not before the effective date of the law implemented by the regulation. 16
- * Sec. 8. Section 7 of this Act takes effect immediately under AS 01.10.070(c). 17
- * Sec. 9. Except as provided in sec. 8 of this Act, this Act takes effect January 1, 2027. 18
+Unique in the Crowd: The privacy bounds
+of human mobility
+Yves-Alexandre de Montjoye 1,2,C e´sar A. Hidalgo 1,3,4, Michel Verleysen 2 & Vincent D. Blondel 2,5
+1Massachusetts Institute of Technology, Media Lab, 20 Ames Street, Cambridge, MA 02139 USA,2Universite´ catholique de
+Louvain, Institute for Information and Communication Technologies, Electronics and Applied Mathematics, Avenue Georges
+Lemaıˆtre 4, B-1348 Louvain-la-Neuve, Belgium,3Harvard University, Center for International Development, 79 JFK Street,
+Cambridge, MA 02138, USA, 4Instituto de Sistemas Complejos de Valparaı´so, Paseo 21 de Mayo, Valparaı´so, Chile,
+5Massachusetts Institute of Technology, Laboratory for Information and Decision Systems, 77 Massachusetts Avenue, Cambridge,
+MA 02139, USA.
+We study fifteen months of human mobility data for one and a half million individuals and find that human
+mobility traces are highly unique. In fact, in a dataset where the location of an individual is specified hourly,
+and with a spatial resolution equal to that given by the carrier’s antennas, four spatio-temporal points are
+enough to uniquely identify 95% of the individuals. We coarsen the data spatially and temporally to find a
+formula for the uniqueness of human mobility traces given their resolution and the available outside
+information. This formula shows that the uniqueness of mobility traces decays approximately as the 1/10
+power of their resolution. Hence, even coarse datasets provide little anonymity. These findings represent
+fundamental constraints to an individual’s privacy and have important implications for the design of
+frameworks and institutions dedicated to protect the privacy of individuals.
+D
+erived from the Latin Privatus, meaning ‘‘withdraw from public life,’’ the notion of privacy has been
+foundational to the development of our diverse societies, forming the basis for individuals’ rights such as
+free speech and religious freedom 1. Despite its importance, privacy has mainly relied on informal pro-
+tection mechanisms. For instance, tracking individuals’ movements has been historically difficult, making them
+de-facto private. For centuries, information technologies have challenged these informal protection mechanisms.
+In 1086, William I of England commissioned the creation of the Doomsday book, a written record of major
+property holdings in England containing individual information collected for tax and draft purposes 2. In the late
+19th century, de-facto privacy was similarly threatened by photographs and yellow journalism. This resulted in
+one of the first publications advocating privacy in the U.S. in which Samuel Warren and Louis Brandeis argued
+that privacy law must evolve in response to technological changes 3.
+Modern information technologies such as the Internet and mobile phones, however, magnify the uniqueness of
+individuals, further enhancing the traditional challenges to privacy. Mobility data is among the most sensitive
+data currently being collected. Mobility data contains the approximate whereabouts of individuals and can be
+used to reconstruct individuals’ movements across space and time. Individual mobility traces T [Fig. 1A–B] have
+been used in the past for research purposes4–18 and to provide personalized services to users19. A list of potentially
+sensitive professional and personal information that could be inferred about an individual knowing only his
+mobility trace was published recently by the Electronic Frontier Foundation20. These include the movements of a
+competitor sales force, attendance of a particular church or an individual’s presence in a motel or at an abortion
+clinic.
+While in the past, mobility traces were only available to mobile phone carriers, the advent of smartphones and
+other means of data collection has made these broadly available. For example, AppleH recently updated its privacy
+policy to allow sharing the spatio-temporal location of their users with ‘‘partners and licensees’’ 21. 65.5B geo-
+tagged payments are made per year in the US 22 while Skyhook wireless is resolving 400 M user’s WiFi location
+every day23. Furthermore, it is estimated that a third of the 25B copies of applications available on Apple’s App
+StoreSM access a user’s geographic location24,25, and that the geo-location of ,50% of all iOS and Android traffic is
+available to ad networks 26. All these are fuelling the ubiquity of simply anonymized mobility datasets and are
+giving room to privacy concerns.
+A simply anonymized dataset does not contain name, home address, phone number or other obvious identifier.
+Yet, if individual’s patterns are unique enough, outside information can be used to link the data back to an
+individual. For instance, in one study, a medical database was successfully combined with a voters list to extract
+SUBJECT AREAS:
+APPLIED PHYSICS
+APPLIED MATHEMATICS
+STATISTICS
+COMPUTATIONAL SCIENCE
+Received
+1 October 2012
+Accepted
+4 February 2013
+Published
+25 March 2013
+Correspondence and
+requests for materials
+should be addressed to
+Y.-A. de M. (yva@mit.
+edu)
+SCIENTIFIC REPORTS | 3 : 1376 | DOI: 10.1038/srep01376 1
+the health record of the governor of Massachusetts 27. In another,
+mobile phone data have been re-identified using users’ top loca-
+tions28. Finally, part of the Netflix challenge dataset was re-identified
+using outside information from The Internet Movie Database 29.
+All together, the ubiquity of mobility datasets, the uniqueness of
+human traces, and the information that can be inferred from them
+highlight the importance of understanding the privacy bounds of
+human mobility. We show that the uniqueness of human mobility
+traces is high and that mobility datasets are likely to be re-identifiable
+using information only on a few outside locations. Finally, we show
+that one formula determines the uniqueness of mobility traces pro-
+viding mathematical bounds to the privacy of mobility data. The
+uniqueness of traces is found to decrease according to a power func-
+tion with an exponent that scales linearly with the number of known
+spatio-temporal points. This implies that even coarse datasets pro-
+vide little anonymity.
+Results
+Uniqueness of human mobility . In 1930, Edmond Locard showed
+that 12 points are needed to uniquely identify a fingerprint 30. Our
+unicity test estimates the number of points p needed to uniquely
+identify the mobility trace of an individual. The fewer points
+needed, the more unique the traces are and the easier they would
+be to re-identify using outside information. For re-identification
+purposes, outside observations could come from any publicly
+available information, such as an individual’s home address,
+workplace address, or geo-localized tweets or pictures. To the best
+of our knowledge, this is the first quantification of the uniqueness of
+human mobility traces with random points in a sparse, simply
+anonymized mobility dataset of the scale of a small country.
+Given Ip, a set of spatio-temporal points, and D, a simply anon-
+ymized mobility dataset, we evaluate e, the uniqueness of traces, by
+extracting from D the subset of trajectories S( Ip) that match the p
+points composing Ip [See Methods]. A trace is unique if jS(Ip)j 5 1,
+containing only one trace. For example, in Fig. 2A, we evaluate the
+uniqueness of traces given Ip52. The two spatio-temporal points
+contained in Ip52 are zone I from 9am to 10am and zone II from
+12pm to 1pm. The red and the green traces both satisfy Ip52, making
+them not unique. However, we can also evaluate the uniqueness of
+traces knowing Ip53, adding as a third point zone III between 3pm
+and 4pm. In this case jS(Ip53)j 5 1, uniquely characterize the green
+trace. A lower bound on the risk of deductive disclosure of a user’s
+identity is given by the uniqueness of his mobility trace, the like-
+lihood of this brute force characterization to succeed.
+Our dataset contains 15 months of mobility data for 1.5 M people,
+a significant and representative part of the population of a small
+European country, and roughly the same number of users as the
+location-based service FoursquareH31.J u s ta sw i t hs m a r t p h o n ea p p l i -
+cations or electronic payments, the mobile phone operator records
+the interactions of the user with his phone. This creates a comparable
+longitudinally sparse and discrete database [Fig. 3]. On average, 114
+interactions per user per month for the nearly 6500 antennas are
+recorded. Antennas in our database are distributed throughout the
+country and serve, on average, , 2000 inhabitants each, covering
+areas ranging from 0.15 km
+2 in cities to 15 km 2 in rural areas. The
+number of antennas is strongly correlated with population density
+(R
+2 5 .6426) [Fig. 3C]. The same is expected from businesses, places
+in location-based social networks, or WiFi hotspots.
+Fig. 2B shows the fraction of unique traces ( e) as a function of the
+number of available points p. Four randomly chosen points are
+enough to uniquely characterize 95% of the users ( e . .95), whereas
+two randomly chosen points still uniquely characterize more than
+50% of the users ( e . .5). This shows that mobility traces are highly
+unique, and can therefore be re-identified using little outside
+information.
+Scaling properties . Nonetheless, e depends on the spatial and
+temporal resolution of the dataset. Here, we determine this depen-
+dence by lowering the resolution of our dataset through spatial and
+temporal aggregation [Fig. 1C]. We do this by increasing the size of a
+region, aggregating neighbouring cells into clusters of v cells, or by
+reducing the dataset’s temporal resolution, increasing the length of
+the observation time window to h hours [see Methods]. Both of these
+aggregations are bound to decrease e, and therefore, make re-
+identification harder.
+Fig. 4A shows how the uniqueness of mobility traces e depends on
+the spatial and temporal resolution of the data. This reduction, how-
+ever, is quite gradual. Given four points (p 54), we find that e . .5
+when using a resolution of h 5 5 hours and v 5 5 antennas.
+Statistically, we find that traces are more unique when coarse on
+one dimension and fine along another than when they are medium-
+grained along both dimensions. Indeed, given four points, e . .6 in a
+dataset with a temporal resolution of h 5 15 hours or a spatial
+resolution of v 5 15 antennas while e . .4 in a dataset with a
+temporal resolution of h 5 7 hours and a spatial resolution of v 5
+7 antennas [Fig. 4A].
+Next, we show that it is possible to find one formula to estimate the
+uniqueness of traces given both, the spatial and temporal resolution
+of the data, and the number of points available to an outside observer.
+Fig. 4B and 4C show that the uniqueness of a trace decreases as the
+power function e 5 a 2 x
+b, for decreases in both the spatial and
+temporal resolution (x), and for all considered p 5 4, 6, 8 and 10 (see
+Table S1). The uniqueness of human mobility can thus be expressed
+using the single formula: e 5 a 2 (nh)
+b. We find that this power
+AB C
+Antenna
+Phone
+activity
+Figure 1 | (A) Trace of an anonymized mobile phone user during a day. The dots represent the times and locations where the user made or received a call.
+Every time the user has such an interaction, the closest antenna that routes the call is recorded. (B) The same user’s trace as recorded in a mobility database.
+The Voronoi lattice, represented by the grey lines, are an approximation of the antennas reception areas, the most precise location information available to
+us. The user’s interaction times are here recorded with a precision of one hour. (C) The same individual’s trace when we lower the resolution of our dataset
+through spatial and temporal aggregation. Antennas are aggregated in clusters of size two and their associated regions are merged. The user’s interaction
+are recorded with a precision of two hours. Such spatial and temporal aggregation render the 8:32 am and 9:15 am interactions indistinguishable.
+www.nature.com/ scientificreports
+SCIENTIFIC REPORTS | 3 : 1376 | DOI: 10.1038/srep01376 2
+function fits the data better than other two-parameters functions
+such as a 2 exp ( lx), a stretched exponential a 2 exp xb,o ra
+standard linear function a 2 bx (see Table S1). Both estimators for
+a and b are highly significant (p , 0.001)32, and the mean pseudo-R2
+is 0.98 for the Ip54 case and the Ip510 case. The fit is good at all levels
+of spatial and temporal aggregation [Fig. S3A–B].
+The power-law dependency of e means that, on average, each time
+the spatial or temporal resolution of the traces is divided by two, their
+uniqueness decreases by a constant factor , (2)
+2b. This implies that
+privacy is increasingly hard to gain by lowering the resolution of a
+dataset.
+Fig. 2B shows that, as expected, e increases with p. The mitigating
+effect of p on e is mediated by the exponent b which decays linearly
+with p: b 5 0.157 2 0.007p [Fig. 4E]. The dependence of b on p
+implies that a few additional points might be all that is needed to
+identify an individual in a dataset with a lower resolution. In fact,
+given four points, a two-fold decrease in spatial or temporal resolu-
+tion makes it 9.3% less likely to identify an individual, while given ten
+points, the same two-fold decrease results in a reduction of only 6.2%
+(see Table S1).
+Because of the functional dependency of e on p through the expo-
+nent b, mobility datasets are likely to be re-identifiable using
+information on only a few outside locations.
+Discussion
+Our ability to generalize these results to other mobility datasets
+depends on the sensitivity of our analysis to extensions of the data
+to larger populations, or geographies. An increase in population
+density will tend to decrease e. Yet, it will also be accompanied by
+an increase in the number of antennas, businesses or WiFi hotspots
+used for localizations. These effects run opposite to each other, and
+therefore, suggest that our results should generalize to higher popu-
+lation densities.
+Extensions of the geographical range of observation are also
+unlikely to affect the results as human mobility is known to be highly
+circumscribed. In fact, 94% of the individuals move within an average
+radius of less than 100 km
+17. This implies that geographical exten-
+sions of the dataset will stay locally equivalent to our observations,
+making the results robust to changes in geographical range.
+From an inference perspective, it is worth noticing that the spatio-
+temporal points do not equally increase the likelihood of uniquely
+identifying a trace. Furthermore, the information added by a point is
+highly dependent from the points already known. The amount of
+information gained by knowing one more point can be defined as the
+reduction of the cardinality of S( I
+p) associated with this extra point.
+The larger the decrease, the more useful the piece of information is.
+Intuitively, a point on the MIT campus at 3AM is more likely to
+make a trace unique than a point in downtown Boston on a Friday
+evening.
+This study is likely to underestimate e, and therefore the ease of re-
+identification, as the spatio-temporal points are drawn at random
+from users’ mobility traces. Our I
+p are thus subject to the user’s
+spatial and temporal distributions. Spatially, it has been shown that
+the uncertainty of a typical user’s whereabouts measured by its
+Figure 2 | (A) Ip52 means that the information available to the attacker consist of two 7am-8am spatio-temporal points (I and II). In this case, the target
+was in zone I between 9am to 10am and in zone II between 12pm to 1pm. In this example, the traces of two anonymized users (red and green) are
+compatible with the constraints defined by Ip52. The subset S(Ip52) contains more than one trace and is therefore not unique. However, the green trace
+would be uniquely characterized if a third point, zone III between 3pm and 4pm, is added (Ip53). (B) The uniqueness of traces with respect to the number
+p of given spatio-temporal points (Ip). The green bars represent the fraction of unique traces, i.e.| S(Ip) | 5 1. The blue bars represent the fraction of | S(Ip) |
+# 2. Therefore knowing as few as four spatio-temporal points taken at random (Ip54) is enough to uniquely characterize 95% of the traces amongst 1.5 M
+users. (C) Box-plot of the minimum number of spatio-temporal points needed to uniquely characterize every trace on the non-aggregated database. At
+most eleven points are enough to uniquely characterize all considered traces.
+10 6
+10 5
+10 4
+10 3
+10 0 10 1 10 2 10 3
+Number of antennas
+Inhabitants
+Probability density function
+Median inter-interactions time per user [h]
+0 12 24 36 48 60 72 84 96
+10 0
+10 -1
+10 -2
+10 -3
+10 -4
+10 0
+10 -1
+10 -2
+10 -3
+10 -4
+10 -5
+ 0 500 1000 1500 2000 2500
+Number of interactions
+Probability density function
+A BC
+Figure 3 | (A) Probability density function of the amount of recorded spatio-temporal points per user during a month. (B) Probability density function
+of the median inter-interaction time with the service. (C) The number of antennas per region is correlated with its population (R 2 5 .6426). These plots
+strongly emphasize the discrete character of our dataset and its similarities with datasets such as the one collected by smartphone apps.
+www.nature.com/ scientificreports
+SCIENTIFIC REPORTS | 3 : 1376 | DOI: 10.1038/srep01376 3
+entropy is 1.74, less than two locations 18. This makes our random
+choices of points likely to pick the user’s top locations (typically
+‘‘home’’ and ‘‘office’’). Temporally, the distribution of calls during
+the week is far from uniform [Fig. S1] which makes our random
+choice more likely to pick a point at 4PM than at 3AM. However,
+even in this case, the traces we considered that are most difficult to
+identify can be uniquely identified knowing only 11 locations [Fig. 2C].
+For the purpose of re-identification, more sophisticated
+approaches could collect points that are more likely to reduce the
+uncertainty, exploit irregularities in an individual’s behaviour, or
+implicitly take into account information such as home and work-
+place or travels abroad
+29,33. Such approaches are likely to reduce the
+number of locations required to identify an individual, vis-a`-vis the
+average uniqueness of traces.
+We showed that the uniqueness of human mobility traces is high,
+thereby emphasizing the importance of the idiosyncrasy of human
+movements for individual privacy. Indeed, this uniqueness means
+that little outside information is needed to re-identify the trace of a
+targeted individual even in a sparse, large-scale, and coarse mobility
+dataset. Given the amount of information that can be inferred from
+mobility data, as well as the potentially large number of simply
+anonymized mobility datasets available, this is a growing concern.
+We further showed that while E* vhðÞ
+b, b , 2p/100. Together,
+these determine the uniqueness of human mobility traces given the
+traces’ resolution and the available outside information. These results
+should inform future thinking in the collection, use, and protection
+of mobility data. Going forward, the importance of location data will
+only increase
+34 and knowing the bounds of individual’s privacy will
+Temporal resolution [h]
+Spatial resolution [v]
+1 cell
+3 cells
+5 cells
+7 cells
+9 cells
+11 cells
+13 cells
+Temporal resolution [h]
+Normalized uniqueness of tracesSpatial resolution [v]
+Temporal resolution [h]
+A B
+Spatial resolution [v]
+Normalized uniqueness of traces
+CD
+15
+13
+11
+9
+7
+5
+3
+1
+1 3 5 7 9 11 13 15
+15
+13
+11
+9
+7
+5
+3
+1
+1 3 5 7 9 11 13 15
+10 0
+10 0
+10 0 10 1
+10 0 10 1
+456789 1 0
+0.06
+0.10
+0.14
+p
+E
+1 hour
+3 hours
+5 hours
+7 hours
+9 hours
+11 hours
+13 hours
+Uniqueness of traces0.70
+Uniqueness of traces0.70
+ β=0.157−0.007p
+Figure 4 | Uniqueness of traces [e] when we lower the resolution of the dataset with (A)p 5 4 and (D) p 5 10 points. It is easier to attack a dataset that is
+coarse on one dimension and fine along another than a medium-grained dataset along both dimensions. Given four spatio-temporal points, more than
+60% of the traces are uniquely characterized in a dataset with an h 5 15-hours temporal resolution while less than 40% of the traces are uniquely
+characterized in a dataset with a temporal resolution of h 5 7 hours and with clusters of v 5 7 antennas. The region covered by an antenna ranges from
+0.15 km 2 in urban areas to 15 km 2 in rural areas. (B–C) When lowering the temporal or the spatial resolution of the dataset, the uniqueness of traces
+decrease as a power function e 5 a 2 xb. (E) While e decreases according to a power function, its exponent b decreases linearly with the number of points
+p. Accordingly, a few additional points might be all that is needed to identify an individual in a dataset with a lower resolution.
+www.nature.com/ scientificreports
+SCIENTIFIC REPORTS | 3 : 1376 | DOI: 10.1038/srep01376 4
+be crucial in the design of both future policies and information
+technologies.
+Methods
+The dataset. This work was performed using an anonymized mobile phone dataset
+that contains call information for ,1.5 M users of a mobile phone operator.
+The data collection took place from April 2006 to June 2007 in a western country.
+Each time a user interacts with the mobile phone operator network by initiating or
+receiving a call or a text message, the location of the connecting antenna is recorded
+[Fig. 1A]. The dataset’s intrinsic spatial resolution is thus the maximal half-distance
+between antennas. The dataset’s intrinsic temporal resolution is one hour [Fig. 1B].
+Unicity test and the likelihood of deductive disclosure . The considered dataset
+contains one trace T for each user. The traces spatio-temporal points contain the
+region in which the user was and the time of the interaction. We evaluate the
+uniqueness of a trace given a set I
+p of p randomly chosen spatio-temporal points. A
+trace is said to be to be compatible with Ip if Ip(T [Fig. 2A]. Note that this notion of
+compatibility can easily be extended to noisier or richer data. A brute force
+characterization is performed by extracting from the entire dataset of 1.5 M users
+S(I
+p), the set of users whose mobility traces T are compatible with Ip. All mobility
+traces in the dataset T are successively tested for compatibility with Ip. A trace is
+characterized ‘‘out of x’’, if the set of traces that are compatible with the points
+contains at most x users: jS(Ip)j # x. A trace is uniquely characterized if the set
+contains exactly one trace: jS(Ip)j 5 1. The uniqueness of traces is estimated as the
+percentage of 2500 random traces that are unique givenp spatio-temporal points. The
+p points composing Ip are taken at random among all the interactions the user had
+with the service. As discussed, we do not apply any constraints regarding the choice of
+Ip.
+Minimum number of spatio-temporal location needed to uniquely characterize
+every trace. Fig. 2B shows that .95 , e , 1 given Ip54. Fig. 2C evaluates the minimum
+p needed to uniquely characterize every trace in a given set. This set contains a
+random sample of 1000 heavy-users, i.e. users that used their phone at least 75 times
+per month as their randomly chosen points might make their trace less unique.
+Spatial aggregation. Spatial aggregation is achieved by increasing the size of the
+regions in which the user is known to be during his interactions with the service. In the
+case of discrete data, a bijective relation exists between antennas (known in this case as
+centroids) and the region defined by the Voronoi tessellation. The tessellation is
+defined so that every point in a region is closer to the region’s antenna than to any
+other antenna. In order to increase the region’s area, one should group antennas into
+clusters of a given sizev. While the problem of optimally grouping places in a 2D space
+into groups of given sizes v is non trivial, it can be approximated through clustering
+methods. The canonical clustering methods focus on minimizing the within-cluster
+sum of squares rather than producing balanced clusters. This drawback can be
+controlled by the use of a Frequency Sensitive Competitive Learning scheme
+35. Fig. S2
+shows the resulting group size histogram optimized for clusters of size 4. Once
+antennas are aggregated into groups, their associated regions are merged.
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+Acknowledgements
+We thank Damien François, Janos Kertesz, Renaud Lambiotte, Vincent Traag and Paul Van
+Dooren for discussions and comments on the manuscript as well as Maxime Melchior for
+sharing computer code and Susie Fu for help with the figures. This work was supported by a
+grant 09/14-017 ‘‘Action de Recherche Concerte´’’ of the ‘‘Communaute´ française de
+Belgique’’ on Information Retrieval in Time Evolving Networks.
+Author contributions
+Y.-A. de M. designed and performed experiments, analyzed data and wrote the paper;
+C.A.H. designed experiments, developed analytic tools and wrote the paper; M.V. and
+V.D.B. designed experiments and wrote the paper.
+Additional information
+Supplementary information accompanies this paper at http://www.nature.com/
+scientificreports
+Competing financial interests: The authors declare no competing financial interests.
+License: This work is licensed under a Creative Commons
+Attribution-NonCommercial-NoDerivs 3.0 Unported License. To view a copy of this
+license, visit http://creativecommons.org/licenses/by-nc-nd/3.0/
+How to cite this article: de Montjoye, Y.-A., Hidalgo, C.A., Verleysen, M. & Blondel, V.D.
+Unique in the Crowd: The privacy bounds of human mobility. Sci. Rep. 3, 1376;
+DOI:10.1038/srep01376 (2013).
+www.nature.com/ scientificreports
+SCIENTIFIC REPORTS | 3 : 1376 | DOI: 10.1038/srep01376 5

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