Hmm - but unacceptable to whom? There are definitely times when I am perfectly 
comfortable self-asserting a false location. In fact, I'd go further and say 
that in general, I have no use for location-based services…
To be honest, I think service providers often get the location-based services 
argument the wrong way round; what's useful to me, as a user, is the ability to 
go online and locate something (say, a restaurant) regardless of *my* current 
location. (So, for instance, I can find out where my hotel in San Diego for 
next week is, even though I'm in the UK). I am less interested in passively 
disclosing my location so that I can be told what is in my immediate vicinity.

I take Martin's point about location fuzzing: the fact that I state a false 
location on Twitter won't fool someone who carefully monitors the times at 
which I tweet… they will quickly figure out that either I often tweet at 3 in 
the morning, or I'm not where I claim to be. But I think we should be careful 
about how we frame the problem and the potential goals. It is almost certainly 
not realistic to aim make it impossible for anyone to de-identify any data 
about me: in privacy terms, it's more viable to aim to raise the threshold of 
data needed for *some* third parties to infringe my privacy. The EU Article 29 
Working Group implies this with its findings on what constitutes personal data. 
Their view is that some items of data (such as an IP address) are sometimes 
personally identifiable and sometimes not, depending on whether a third party 
is in a position to link them to other data items. Thus, as far as my ISP is 
concerned, my IP address is easy to link with a subscriber address… whereas to 
most other third parties, it is a relatively fuzzy identifier.

Bottom line: I'm not sure if the required action here is further research work 
or changes to the draft, but I do think the problem would benefit from being 
explored and defined more fully…

HTH,
Robin


Robin Wilton
Technical Outreach Director - Identity and Privacy
Internet Society

email: [email protected]
Phone: +44 705 005 2931
Twitter: @futureidentity

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