Simon Hania van TomTom over Big Data in de workshop op de SURFnet Relatiedagen 2012

1. Big data – Big brother?
Using geolocation in a trustworthy and compliant way

2. More than SatNavs…
Consumer Automotive
Business Solutions Licensing
2 09/10/2012

3. Revolutionising navigation
In 4 steps
4. TomTom HD Traffic 4. TomTom HD Traffic
3. IQ Routes 3. IQ Routes
2. Map Share 2. Map Share
1. Base maps 1. Base maps
4. TomTom HD Traffic 4. TomTom HD Traffic
3. IQ Routes 3. IQ Routes
2. Map Share 2. Map Share
1. Base maps 1. Base maps
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4. Community input – with permission
We profile roads, not people
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5. TomToms trip archive
Anonymous location and speed information from the
TomTom user community
5 billion (10E9) speed measurements per day
5 trillion (10E12) speed measurements to date!
by customers driving 50 billion kilometres
and visiting every spot over 1,000 times

6. Creating TomTom HD Traffic: data sources
Range of high-quality real-time data sources
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7. TomTom HD Traffic coverage
It covers up to 99.9% of all roads
LONDON
TMC coverage HD Traffic coverage
Check for yourself on tomtom.com/livetraffic or use the
7 free TomTom Places App for iPhone or Android

8. Intersection analysis
Obsoletes time-consuming, expensive and inaccurate methods
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9. Travel times to hospital
The reality check that can help to save lives
LONDON
Based on theoretical Based on real world
maximum speeds measurements
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10. Origin/Destination analysis
Example: Trips with Frankfurt Airport as destination
• Where are your
customers coming
from?
• What routes do they
take?
• How may drivers are
passing?
• Etc.
• Combine with other
geo-based data
sources for additional
analysis
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11. Location privacy is top of mind
With bloggers, press, regulators, enforcers, legislators and many
users
• TomTom investigated by
leading European Data
Protection Authority in 2011
• TomTom’s use of location
data is in accordance with
EU Data Protection Laws
• Processing and delivery to
third parties 100% OK
• Informing users needed to
be more explicit, including
opt-in
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12. Drivers, police & TomTom
An explosive mixture
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13. Privacy, amongst others, is about the
protection of personal data
Personal data:
• Contains (whatever) information
relating to a natural (“real”) person
• That person could be
identified, directly or indirectly
• Typically: data attached to unique
identifiers
Anonymous only:
• When no reasonable way exists to
identify (“single out”) a person
• Even when requiring correlation with
other data sources (e.g. maps and
phonebooks)
• By anyone with the right resources
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14. EU WP29 opinion “Geolocation services on smart mobile devices”
Beware: engineers’ “binary” interpretation of principle based law with open norms
• Data attached to a unique identifier (e.g. serial number, email address) or reversible
pseudonym (e.g. a hash) is to be considered personal data
• Location data originating from any individual is to be considered sensitive personal data:
consent is the only acceptable legal basis for processing
• Sending location data “off board” requires:
• Freely given no pressure is felt to consent
• Prior before processing starts
• Informed explain purpose, duration and who has access
• Explicit i.e. opt-in requiring a user action and separate from accepting T&C’s
• Consent permission to go ahead
• Information is required regarding:
• What data is processed
• Who will have access
• Why is the data used
• When will it be deleted
• Where will the data be processed
• Validity of consent is directly related to the quality of information towards the user
• Consent renewal is required after prolonged period of non-use and at least every year
• No feature creep: perfectly stick to the purpose as agreed to by the user
• Erase location data right after use and never keep longer than 24 hours
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15. Typical personal data misconceptions
very often present in technology companies
• We do not identify the user while using the data, so we have no
issues with privacy law
• We only use the unique serial number of the users device, so
the data is anonymous and we have no issues with privacy law
• We encrypt the data, so we are no longer
using/receiving/sending personal data
• We use hashes to replace all serial numbers, so the data is now
anonymous and we have no issues with privacy law
• We anonimize the data, so we are not using personal data
• We can use the users’ data for anything we want, as long as we
keep the data to ourselves
• Look: big name companies are doing the same, so we are OK
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16. TomTom & Privacy
Vision: Principles:
Community input (crowd 1. Avoid unpleasant surprises:
sourcing) is strategic • Customer insight is
paramount
Privacy helps to realize business • Be open and explain –
objectives by ensuring trust hesitation is an omen
• Keep it simple
Privacy is integral part of business 2. The customer remains in
continuity above and beyond legal control of his personal data: we
compliance have it “on a loan”
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17. Avoiding re-identification is key
TomTom has a strict code of conduct to adhere to privacy laws
1 month • Historic trip archive only
to be used for road,
traffic and related
purposes
• No access to raw data
outside TomTom, ever
• TomTom performs
1 day processing
• TomTom ensures re-
identification is
impossible e.g. through
sufficient aggregation
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18. Community input – with permission
We profile roads, not people
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19. Multi-disciplinary approach
Don’t just leave it to the lawyers
explanation & permission
engineering & operations
Expectation & law
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20. Recommendations
• Incorporate data protection requirements from the start
• Take a multi-disciplinary approach: it is about your
“license to operate in the information society”
• Embed “privacy by design” into development processes
• Document your data: “what, why, when, who, where”
• Appoint a “privacy czar” in your organization
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21. References
• The EU Data Protection Directive (Directive 95/46/EC):
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31995L0046:en:HTML
• Working Party Article 29 opinion 13/2011 on "Geolocation services on smart mobile devices”
http://ec.europa.eu/justice/policies/privacy/docs/wpdocs/2011/wp185_en.pdf
• Working Party Article 29 opinion 15/2011 on "Consent”
http://ec.europa.eu/justice/policies/privacy/docs/wpdocs/2011/wp187_en.pdf
• The report on the Dutch Data Protection Authority investigation on TomTom's use of location
data (in English):
http://www.dutchdpa.nl/Pages/en_pb_20120112_investigation-tomtom.aspx
• “How we use your data”: TomTom’s explanation on its use of location data
http://www.tomtom.com/yourdata
video: http://www.youtube.com/watch?v=ZfRkAQl2wWQ
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