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Cybersecurity & Standards, Government Surveillance, Privacy & Data

Report: Use of Aggregated Location Information and COVID-19

As government leaders, policymakers, and technology companies continue to navigate the global coronavirus pandemic, CDT is actively monitoring the latest responses and working to ensure they are grounded in civil rights and liberties. Our policy teams aim to help leaders craft solutions that balance the unique needs of the moment, while still respecting and upholding individual human rights. Find more of our work at

Use of Aggregated Location Information and COVID-19: What We’ve Learned, Cautions about Data Use, and Guidance for Companies [PDF]

Over the last few months technology and data have featured prominently in discussions of how governments, public health officials, employers, and others should respond to the challenges presented by COVID-19. The Center for Democracy & Technology has expressed preliminary thoughts on the principles that should guide government responses that include the use of data and technology. In those principles we voiced a preference for disclosure of aggregated data which can provide useful insights to public health officials. This short paper builds on that statement and reviews some of the disclosures of aggregated mobility data that have been made, its utility, and what companies who seek to disclose these and other forms of aggregated data should take into consideration in order to preserve privacy and aid public health policy.

Location information is sensitive and should enjoy strong privacy protections. When used inappropriately, location data can lead to financial, reputational, or even physical harm. Sharing any sort of location information should be consistent with modern concepts of privacy, including recent Supreme Court precedent. This is especially important when location information is shared with the government. Thankfully, there are examples where location data can be utilized in a manner that both recognizes and protects individual user privacy, while also offering insights that can benefit public health and efforts to combat COVID-19. The key to striking an acceptable balance is using and offering data that has been stripped of individual identifiers in sufficiently large samples. Even with privacy protecting considerations, however, it is vital to understand the limits of these offerings. They almost always represent segments of the population; they have gaps, and do not represent every community equally.

Public health policy and efforts to thwart COVID-19 must be led by experts using multiple tools. Aggregated location data has emerged as an intriguing and potentially powerful tool, but it is not an illusive “silver-bullet” that, once deployed, will put an end to the global pandemic. Instead, when designed to account for individual privacy and underrepresented communities, aggregated location data may be one part of a larger strategy to keep us all healthy, safe, and informed.