Claim that Anonymization is Impossible Unsupported

Claim that Anonymization is Impossible Unsupported

Lenard Files Comments to FCC on Sharing of CPNI

Contact: Amy Smorodin
(202) 828-4405

January 17, 2014 – The assertion in a recent petition by public interest groups that it is impossible to anonymize data does not stand up to scrutiny, states Technology Policy Institute President Thomas Lenard in comments filed with the Federal Communications Commission. The agency should not base any decisions on this faulty analysis, which could have broader implications beyond sharing of customer proprietary network information (CPNI).

The interest groups’ petition requests that carriers should only be able to share aggregated data with third parties because de-identified call records still constitute identifiable CPNI. Lenard shows that the studies cited by the petitioners do not support their claim that anonymization is not possible. Moreover, “the petitioners do not analyze the carriers’ methods of anonymizing CPNI data or in any way show that their methods are deficient. The petition contains no examples of CPNI having been successfully re-identified or misused.”

“The proper method of anonymizing data is a legitimate topic for discussion, but the notion that anonymization is not possible or that any reasonably competent computer science graduate student can easily re-identify anonymized data is not correct,” Lenard concludes. Moreover, acceptance of the claim that anonymization of data is impossible would adversely affect a broad array of commercial activity and research. “Whatever the Commission decides, it should not base its decision on the notion that data cannot be de-identified.”

Lenard’s comments are available on the TPI website.

The Technology Policy Institute

The Technology Policy Institute is a non-profit research and educational organization that focuses on the economics of innovation, technological change, and related regulation in the United States and around the world. More information is available at https://techpolicyinstitute.org/.

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