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Location Based Services – The UK Experience How do location based services work?
When you turn on your mobile phone your SIM card connects to its GSM or 3G network through the nearest available radio cell.
Your networks know where each cell is, so they know where you are or where you were.
Location Based Services Big change
In the past, in emergencies or on the production of a warrant, the police or emergency services have been able to obtain information about a person’s past or present whereabouts.
Now the networks are selling this data or using it to sell new services.
Location Based Services Two types of location based services
Where the SIM card asks the network for information e.g. where is the nearest railway station, Chinese restaurant, pharmacy or ATM?
Few, if any, safety or privacy issues arise here. There are only two parties to the transaction. However this could change if age sensitive products, services or venues started to be promoted in this way.
Where a third party requests information about another person’s whereabouts.
The person to be located, the “locatee”, is “passive” in that they are not asked to do anything to facilitate or allow their whereabouts to be disclosed at that precise moment. They will previously have been asked to agree to going on the service.
Location Based Services Accuracy of data
With passive services the level of accuracy in pinpointing someone’s whereabouts depends entirely on the density of network cells within a given area. In major urban areas, with a high density of cells, it can get you within 100 metres e.g. it can provide the name of a street.
In rural areas the level of accuracy can be very low e.g. within 20 square kilometres.
When associated with GPS (satellite based) it can get to within a few metres in outdoor areas. This is not yet operational within the UK, but the technology and the handsets are available.
Location Based Services UK Code on Location Services
The children’s charities expressed reservations about the role passive location services might play within family life, and questioned what exactly such services might contribute to good parenting. However, unlike sections of the mass media, we did not oppose the new services in principle. We could see that in certain, perhaps limited, circumstances such services may be useful but, anyway, each family must make its own decisions about such things.
Our concern was to ensure that systems were put in place to minimise the risk that location services would be used by unauthorised or inappropriate people in ways which might put children in danger.
We focused our attention on the signing on procedures. We were also mindful of the relevant EU Regulations:
Location Based Services Directive on Privacy and Electronic Communications (2002/58/EC) Article 9 Location data other than traffic data 1. Where location data….relating to users or subscribers of public communications networks or publicly available electronic communications services, can be processed, such data may only be processed when they are made anonymous, or with the consent of the users or subscribers to the extent and for the duration necessary for the provision of a value added service. The service provider must inform the users or subscribers, prior to obtaining their consent, of the type of location data…..which will be processed, of the purposes and duration of the processing and whether the data will be transmitted to a third party for the purpose of providing the value added service. Users or subscribers shall be given the possibility to withdraw their consent for the processing of location data other than traffic data at any time. 2. Where consent of the users or subscribers has been obtained for the processing of location data….. the user or subscriber must continue to have the possibility, using a simple means and free of charge, of temporarily refusing the processing of such data for each connection to the network or for each transmission of a communication." (my italics)
Location Based Services Self-regulatory code agreed
Following a tri-partite negotiation involving the children’s charities, the Government/police and the Networks/ location service providers, a self-regulatory code was agreed and is now in place. Copies have been circulated or are available online at
The networks have incorporated it into their contracts with the location service providers.
Still need to agree a mechanism for reviewing the effectiveness of the code – and for coping with changes in technology e.g. the emergence of new types of phones. Also the emergence of new games consoles which utilise SIM cards and SMS messaging, linked to location based games, may prove to be a challenge.
Location Based Services It’s not the technology Stupid!
It was comparatively easy to agree a code with the mobile companies. They are relatively few in number, and they are already big, consumer-facing companies with a developed sense of corporate social responsibility.
However, what we are now seeing is the emergence of GPS, RFID, stronger versions of Bluetooth and wifi, and doubtless other things yet to come, which can do the same sorts of things, particularly in the field of location based games played via handheld consoles.
Exactly the same issues of principle arise in relation to them yet, right now, there is no obvious route for agreeing a code which would also cover them.