CDT’s Letter to the District DOT Regarding Mobility Data

Shared mobility services, including ride shares, scooters and bikes, have experienced a growth in usage across the United States. In order to effectively manage their streets and public spaces, cities have begun compelling data from the operators of these services reflecting service usage, including in some cases real-time location data.

Today the Center for Democracy & Technology sent a letter to the District of Columbia’s Department of Transportation (DDOT), highlighting concerns we have with the DDOT’s decision to compel mobility service providers to disclose sensitive location information reflecting the travels of their customers. The DDOT decided to adopt the Mobility Data Specification (MDS), and we have been informed that they intend to also compel providers to disclose some of the data in real time, or near real time. We have many concerns with the adoption of MDS. Location data, even de-identified (not directly tied to a credit card or customer profile) is very difficult to anonymize, and we are concerned that the data the DDOT intends to compel could be associated with an individual traveler.

Location data is a sensitive category of personal data that “provides an intimate window into a person’s life, revealing not only his particular movements, but through them his ‘familial, political, professional, religious, and sexual associations.’” We urged the DDOT to adopt a different approach to data reporting, preferably one limited to the reporting of aggregated data, rather than individual trip level data. Properly aggregated, such data can serve legitimate city planning needs and protect privacy at the same time.