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Posted in Consumer Privacy

Automakers Come Together to Adopt Privacy Commitments for Connected Cars with Hogan Lovells’ Assistance

The Alliance of Automobile Manufacturers and the Association of Global Automakers, the two leading trade associations for vehicle manufacturers, today unveiled a set of baseline protections for consumer’s personal information in the era of connected cars. The Privacy Principles for Vehicle Technologies and Services commit participating automakers to take important steps to protect the personal information retrieved from vehicles. Hogan Lovells was engaged by the Alliance to lead drafting of the Principles and a team led by Chris Wolf and including Tim Tobin and James Denvil worked on the project.

As one publication put it, “The world’s automakers have a message for customers: where you drive and how you drive is your business, not ours.”

The Principles build on the Fair Information Practice Principles, Federal Trade Commission guidance, and the White House Consumer Privacy Bill of Rights to deliver updated protections for the personal information of owners. Key features of the Principles include:

  • Transparency regarding how automakers collect, use, and share information retrieved from vehicles ;
  • Heightened protections for sensitive types of consumer data; and
  • Limitations on the sharing of geolocation information with government authorities.

In particular, sensitive personal information like geolocation, biometric and driver behavior information may not be used for first party marketing without affirmative consent of consumers and may not be shared with unaffiliated third parties without permission.  There also are important restrictions on sharing geolocation information with law enforcement.

Hogan Lovells’ Chris Wolf commented:  “This kind of industry-wide commitment to privacy for Internet of Things technologies is exactly what the FTC and the White House called for, and it has been exciting to be involved from the beginning in helping the automotive industry.  The Principles reflect a smart adaptation of the FIPPS and provide consumers with transparency and important choices.”

The Principles have been very well received in the regulatory/academic/advocacy community, as reflected here:

Maureen Ohlhausen – Federal Trade Commission Commissioner:

“The mobile landscape changes quickly, and those who understand it best are the companies who are using new technologies to advance customer value. Self-regulatory approaches, like the Privacy Principles for Vehicle Technologies and Services, allow consumers as well as industry members to benefit from these advances without unintentionally slowing the pace of innovation.”

Jules Polonetsky – Future of Privacy Forum:

“New technologies in vehicles promise drivers real advances in safety and convenience, but will only be welcomed by consumers if they can be sure their personal data will be handled in a trustworthy manner. These privacy principles set a responsible course for new uses of biometric, behavioral and location data and should help avoid any privacy bumps in the road.”

Paul M. Schwartz, Jefferson E. Peyser Professor of Law, Berkeley Law School; Director, Berkeley Center for Law & Technology

“Emerging automotive technologies and services offer great promise for safety, environmental protection, and consumer convenience.  These Principles now advance the privacy dialogue in essential ways.  The Alliance of Automobile Manufacturers and Global Automakers merit an extended round of applause for this document.”


For the Alliance of Automobile Manufacturers’ press release, click here.

To view the Privacy Principles for Vehicle Technologies and Services, click here.