RE: [pdp-pcceg-feb06] References to Traffic Data Provision

["Neuman, Jeff" <Jeff.Neuman@xxxxxxxxxx>]

Thanks Philip.  And on your example, is that prohibited?  

Namely, is it prohibited that the grocery store collect that
information?

Put another way, is it prohibited for the grocery store to provide
information to any third party that XYZ product was bought in my store
500 times on Mondays, 1000 times on Tuesdays . . . and 10,000 times
weekly?  

I understand if you say John Smith purchased this product 10 times a
year, that is personal information and may be protected.  But what if
you tell the vendor (or even the public at large) that of the 100,000
shoppers we had this week, 10,000 bought XYZ product?  Is that
information protected under the law?  

The answer is no.

Jeffrey J. Neuman, Esq. 
Sr. Director, Law, Advanced Services  & Business Development 

NeuStar, Inc. 



-----Original Message-----
From: owner-pdp-pcceg-feb06@xxxxxxxxx
[mailto:owner-pdp-pcceg-feb06@xxxxxxxxx] On Behalf Of Philip Sheppard
Sent: Wednesday, January 17, 2007 10:35 AM
To: pdp-pcceg-feb06@xxxxxxxxxxxxxx
Subject: [pdp-pcceg-feb06] References to Traffic Data Provision


Jef raises an interesting question and one that begs the questions /
observations:
- if the data in question is truly non-personal what is its commercial
value in collection?
- in the EU the assumption is that data should not be used for purposes
other than that
originally intended - I believe there is a precautionary principle here.
- are there mechanisms where non-personal data may be combined with
other data and the
result will be personally identifiable data ?

On point three, by way of example, grocery bar codes and RFID chips
compile non-personal
data but once combined with data from shoppers loyalty cards, the result
is a
commercially-rich data base of individual shopping patterns.

Philip