"Consumer Privacy and Air Travel: Recommendations to the U.S. Dept. of Transportation"

[ACACP in session, 21 May 2013. Left to right: Lisa Madigan, chair (Attorney General of Illinois), Charlie Leocha (Founder and Director, Consumer Travel Alliance), Deborah Ale Flint (Executive Director, Oakland Airport), David Berg (General Counsel, “Airlines For America”)]

I’m on my way to Washington to take part in an unprecedented discussion on Tuesday with the U.S. Department of Transportation about “the privacy of personally identifiable information collected in connection with the purchase of air travel from airlines and travel agents”.

I’ll be the sole consumer advocate appearing before the DOT Advisory Committee for Aviation Consumer Protection, at the end of a day of presentations by Federal and state government agencies and representatives of airlines, travel agencies, and CRSs/GDSs.

I first wrote about the privacy of travel information, well before 11 September 2001, as a consumer issue. For more than a decade, the focus of public attention and of much of my work has shifted to government access to and use of this data. But I have never lost site of my initial and ongoing concerns about the commercial use of travel information.

This meeting is only a first step, and one that is long overdue. But it is also a long-awaited milestone in my work and that of many allies including readers of this blog in the USA and around the world. Thank you for helping get this issue on the DOT’s agenda.

I hope to see some of my DC friends at the meeting. (It’s open to the public, but you must register in advance to attend.) For those who can’t be there, here are the slides of my presentation, including my recommendations for initial DOT actions, and background information including additional references I’ve submitted for the record of the meeting:

• My slides: Consumer Privacy and Air Travel: Recommendations to the U.S. Department of Transportation
  
  
• Meeting information
  
  
• Agenda and witness list (draft, subject to change)
  
  
• Privacy and Travel Data (comments of Edward Hasbrouck, Consumer Travel Alliance, Consumer Federation of America, and Center for Financial Privacy and Human Right to the FTC Privacy Roundtables, 6 November 2009)
  
  
• Privacy and other issues with IATA’s request for approval of its Resolution 787 on personalized pricing (my comments to the DOT, 1 May 2013)
  
  
• Privacy issues with government access to and use of travel information (my presentation at the Cato Institute and on C-SPAN, 2 April 2013)
  
  
• Slides of all presentations
  
  
• Docket folder at Regulations.gov for the ACACP meeting
  (will eventually include full transcript and other information submitted for the record)

My recommendations for first steps by the DOT, in summary:

1. Require airline privacy policies to be included in conditions of carriage.
2. Add a “privacy” tab to the DOT aviation consumer protection Web site including information on the privacy obligations of airlines, travel agencies, and CRSs’/GDSs, and on DOT privacy complaint procedures. Log and report privacy complaints as a distinct category.
3. Establish a working group and publicly-designated point of contact within the DOT specifically charged with responsibility for privacy policy, privacy enforcement, and consultation and coordination with other agencies on privacy policy and enforcement issues.

[Update: Privacy and travel — the DOT starts to take a look (report on the meeting by ACACP member Charlie Leocha). Will DOT finally take traveler privacy issues seriously? (Dennis Schaal, Skift): “Considering the way companies throughout the travel industry view consumer data … as a commodity, it is high time that the DOT began taking privacy issues seriously.”]