FCC Tackles Mobile Broadband Measurement through Prism of Privacy

FCC attorney James Miller, who will head the effort to develop a disclosure statement, said he expects privacy to “guide much of the technical discussion” of what data are collected, and what data are released. No data have been collected, but a draft privacy policy and implementation review document shows the commission is considering three sources of data: Handset data could include details on a user’s operating system version and CPU model. Internet Protocol active measurements could include data on upload and download speed, Web page loading, video streaming performance, and latency and packet loss. Network information could include signal strength, active cell tower identification, and the location’s GPS device.

It’s that last bit that particularly concerns Miller, who spoke of the danger of “time and space elements” that, read together, might produce “breadcrumbs” that someone could follow. Measurements in different locations, correlated in time, could show the location of someone moving from one cell tower to another, he said. That kind of information could be “potentially exposed in the context of the raw data,” he said. So before the raw data are released, the commission may have to “sanitize” the data, perhaps by aggregating them, he said. For instance, the commission could replace a specific host ID with more general geography data in order to obscure the user’s location. “We won’t gather any data unless there’s an agreement in place, and consent from the consumer,” Miller said.

Protecting consumer rights and privacy is “probably the most important issue for us,” said Walter Johnston, chief of the Electromagnetic Compatibility Division in the FCC Office of Engineering and Technology. “It might mean that we have to redact some data. … But always the privacy policy is going to control everything.” Miller noted that the commission is not planning to look at the content of any data going in or out of the phone, such as usage patterns, search criteria, or Web pages that a user is looking at. “We are not doing any sort of inspection,” he said. “We are taking a software application that the customer has voluntarily agreed to install, and executing a test to a website.”

That software application will only work on Android phones to start, and programmers are currently working on the latest iteration of the interface, Salter said. An iPhone port will come later, but Android is “a great one to start with” because the operating system “gives you such a rich data set,” he said. “Out of the box, Android gives you so much stuff, and Apple a lot less.” In fact, Apple’s latest operating system exposes less data than its previous one. Salter said they might try to set up a meeting with Apple to discuss data collection on its “closed platform."

On the wired broadband measurement side, the commission had planned to release a new Measuring Broadband America report this month, but Superstorm Sandy threw a wrench in their plans, officials said. “I was stuck in New York without power for over a week,” Johnston said. The group wanted FCC staff to have three weeks to examine the data, but because of delays from Sandy, officials just got their first look at the data this week, he said. “There’s an awful lot of cross-checking we do just to make sure the data looks sane, and we can put out something that we can stand behind.” Facing the upcoming Christmas holiday, it’s “questionable” that the report will be released this year, Johnston said.

With two wireline reports under its belt, FCC officials are taking suggestions on “possible special studies” that could look into how efficiently data are transported within the home, and “impediments that might exist” to utilizing all the available speed, Johnston said. The commission has also been asked “from a number of quarters” to include metrics on “the state of the Internet,” in terms of “things that the Internet is evolving towards” in security or addressing, he said. Possible future projects including looking at IPv4 versus IPv6, DNSSEC deployment, and analyzing the impact of legacy modems on data throughput, officials said.