Could Contact Tracing in the COVID-19 Era Become Unreasonable Search?
People should be very concerned about the privacy implications of these programs, which seek to gather personal information such as health and location data.
May 18, 2020 at 10:01 AM
5 minute read
As states across the country get back to business, scientists and public health professionals are cautioning that testing and contact tracing must be in place if we have any hope of preventing future outbreaks of the coronavirus. Countries in Europe and Asia have adopted programs to identify potential carriers and track their interactions, but the United States is just beginning to look at how a successful tracing program can be implemented and managed.
In a nutshell, the point of contact tracing is to identify where people who've tested positive for COVID-19 go and with whom they've interacted. Tracing necessarily implicates information of more than one person. Once the subject of tracing has opted in and agreed to be tracked, they've opened the door for friends, colleagues and casual acquaintances to be on the government's radar screen.
It sounds like something out of 1984 or Brave New World. People should be very concerned about the privacy implications of these programs, which seek to gather personal information such as health and location data. On April 30, Senators Roger Wicker (R-Miss.), John Thune (R-S.D.), Jerry Moran (R-Kan.), and Marsha Blackburn (R-Tenn.) introduced legislation that they claim "would provide all Americans with more transparency, choice, and control over the collection and use of their personal health, geolocation, and proximity data."
The COVID-19 Consumer Data Protection Act (CCDPA) covers "precise location data" and "proximity data," which the bill defines as a person's past or present physical location, and it would require companies to disclose to consumers at the point of collection how their data will be handled, to whom it will be transferred, and how long it will be retained. Companies would be obligated to delete or de-identify all personally identifiable information when it is no longer being used for the COVID-19 public health emergency.
It sounds good, but if you're a criminal defendant, it could be horrific. You could find yourself kissing rights guaranteed to you under the constitution goodbye. Think of all the ways your personal information could be used, starting with providing your exact location to law enforcement when it lacks probable cause for a search warrant. It's no stretch to envision searches and seizures that would otherwise run afoul of Fourth Amendment protections arising out of contact tracing.
What's to stop the government from using your geolocation data to build probable cause, to find and arrest you when they would not otherwise have had that ability? What's to prevent police from tracking you through another party's proximity information? How easy could it be to use your information to track down cohorts, individuals for whom there was no probable cause or reasonable suspicion? Location data could suddenly provide law enforcement with carte blanche to go after suspects in contravention of centuries of established legal principle. When society stops protecting the rights of those suspected of crimes, it stops protecting everyone's rights.
The CCPA, as drafted, would apply only to companies subject to Federal Trade Commission regulation, as well as not-for-profit entities and common carriers. It does not cover governmental entities, such as police departments and prosecutors. It authorizes state attorneys general to enforce its provision and provides no private right of action.
Who will monitor how your information is collected, and who will ensure that it is used only for pandemic-related purposes? Once the information is no longer needed for the public health emergency, who will confirm that it has been de-identified or destroyed? How will your interactions and connections be forgotten?
Traditional tracing methods involve manually recording who has tested positive and everyone they've been in contact with in recent weeks. Technology companies, including Google and Apple, have developed software applications to help governments track the spread of COVID-19 using Bluetooth technology. The ramifications of these developments are frightening. Just as with DNA data—which has been repurposed from ancestry sites to assist with cold-case criminal investigations—geolocation and proximity data could become a never-ending resource for law enforcement.
We've unwittingly and unwarily given up claims to personal privacy simply by virtue of being part of the cell-phone, laptop, tablet, cloud-driven world we live in. It will be difficult to unwind the spool into which we've happily entered. But there is a way to remove blinders and look carefully at what is happening in this moment. It is absolutely critical that we arrest and reverse the spread of the coronavirus, but our constitutional rights don't need to become the next victim of the pandemic. Any data privacy protections must include unconditional restraints on government's use of our personal information.
Lara Yeretsian is a Los Angeles criminal defense attorney and principal of Yeretsian Law. She worked on the legal teams defending Michael Jackson, Scott Peterson and other high-profile criminal prosecutions.
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