CHP: Third-Party Geolocation Data Providers
| Tracking # |
033-21-0640 |
| Submitted | May 20, 2021 |
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Communications
From: Bennett Cyphers
To Whom It May Concern:
This letter constitutes a request under the California Public Records Act (CPRA) by the Electronic Frontier Foundation (EFF) for records related to the acquisition and use of geolocation data. We’re looking for records describing how your agency uses location data collected from smartphones and other connected devices, obtained from or processed by third-party data brokers or other providers.
For the purposes of this request, the term “geolocation data” refers to GPS data acquired from cell phones, cell phone applications, other connected consumer devices, or from third-party aggregators of such data, which pertains to the location of individual persons or devices, whether identified or de-identified.
We request the following records for the period between January 1, 2019 and the present:
- All contracts (or records referencing the purchase, acquisition, subscription to, or payment or written agreements) between the California Highway Patrol (CHP), or consultants thereof, and any third-party providers of geolocation data;
- Any records concerning any grants or outside sources of funding relating to or used for the acquisition of geolocation tracking technologies;
- All presentations, marketing materials, or proposals by contractors, subcontractors, or consultants working with CHP relating to the use of geolocation data;
- All technical documentation, guides, presentations, or policies describing access to, storage of, or use of geolocation data;
- All privacy policies, memoranda of understanding, data-sharing agreements, or terms of use applying to geolocation data;
- Any communications between CHP and another agency of this state that relate or refer to sharing of geolocation data; and
- Any communications between CHP and any third-party providers of geolocation data which contain any of the following terms:
- “Mobile device data”,
- “GPS”,
- “Geolocation”,
- “Origin-destination”, or
- “OD data.”
In addition we request the following information and assistance, as required under CPRA:
- Assistance in identifying additional records and information that will help understand how CHP uses geolocation information acquired from third parties;
- A description of the information technology and physical location in which the records exist; and
- Suggestion for overcoming any practical basis for denying access to the records and information sought.
The CPRA also requires you to undertake reasonable efforts to locate responsive records and to work in good faith with requesters to respond to their request. See CYAC v. City of National City, 220 Cal.App.4th 1385, 1430 (2013). Thus under the CPRA you are obligated to conduct a reasonable search and cannot deny a request merely because it might generate a large volume of records.
We ask that you please respond to this request within 10 days either by providing all the requested records or by providing a written response setting forth the legal authority on which you rely in withholding or redacting any document, as well as stating when documents will be made available.
We also request that any records maintained in an electronic format be provided in that same format (such as a PDF, CSV or XLS file), to avoid copying costs.
However, should you be unable to do so, EFF will reimburse you for the direct costs of copying these records (if you elect to charge for copying) plus postage. If you anticipate that these costs will exceed $25.00, or that the time needed to copy the records will delay their release, please contact me so that I can arrange to inspect the documents or decide which documents I wish to have copied. Please also provide and invoice and a cost breakdown of the fee estimate. If the fees are less than $25.00, please copy and send the records and invoice as soon as possible, and we will promptly pay the required costs.
Thank you for your consideration of this request. If you have any questions or concerns, or if I can provide any clarification that will help identify responsive documents or focus this request, please do not hesitate to contact me at (518) 536-8294 or bennett@eff.org. You may also mail correspondence to the Electronic Frontier Foundation, 815 Eddy. St. San Francisco, CA, 94109.
Sincerely,
Bennett Cyphers
From: California Highway Patrol
Good Day Mr. Cyphers,
Attached is the copy of the CHP 370C documenting your request for records pursuant with the California Public Records Act and the Office of Risk Management, Public Records Unit is processing.
For any media related questions, personnel from the Office Community Outreach and Media Relations have been carbon copied in this email and can be contacted at (916) 843-3310.
Thank You,
Anne Ocon
Office Technician
Office of Risk Management
Public Records Unit
(916) 843-4030
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws, including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.
From: Muckrock Staff
To Whom It May Concern:
I'm following up on the following California Public Records Act request, copied below, and originally submitted on May 20, 2021. You had previously indicated that it would be completed on June 1, 2021. I wanted to check on the status of my request, and to see if there was a new estimated completion date.
Thanks for your help, and let me know if further clarification is needed.
From: California Highway Patrol
Good morning,
The Office of Risk Management, Public Records Unit (PRU) sent the attached correspondence to Mr. Cyphers on June 1, 2021.
Please feel free to connect if you have any questions.
Thank you.
Rachna Sharma
Associate Governmental Program Analyst
Office of Risk Management, Public Records Unit
California Highway Patrol
(916) 843-4030 (Main)
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.
From: California Highway Patrol
Good Day,
Please see the attached letter pertaining to your California Public Records Act request.
For any media related questions, personnel from the Office of Community Outreach and Media Relations have been carbon copied in this email and can be contacted at (916) 843-3310.
If you have any questions or require additional assistance pertaining to your California Public Records Act request, please contact any member of the Public Records Unit at (916) 843-4030.
Thank you,
Rachna Sharma
Associate Governmental Program Analyst
California Highway Patrol
Office of Risk Management
Public Records Unit
(916) 843-4030
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws, including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.
From: Muckrock Staff
To Whom It May Concern:
I'm following up on the following California Public Records Act request, copied below, and originally submitted on May 20, 2021. You had previously indicated that it would be completed on June 1, 2021. I wanted to check on the status of my request, and to see if there was a new estimated completion date. You had assigned it reference number #033-21-0640.
Thanks for your help, and let me know if further clarification is needed.
From: California Highway Patrol
Good morning,
Thank you for your email.
The Office of Risk Management, Public Records Unit (PRU) sent the attached correspondence to Mr. Cyphers on June 15, 2021.
Please don’t hesitate to connect if you have any questions.
Rachna Sharma
Associate Governmental Program Analyst
Office of Risk Management, Public Records Unit
California Highway Patrol
(916) 843-4030 (Main)
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.
From: California Highway Patrol
Please see the attached documents regarding your California Public Records Act request.
For any media related questions, personnel from the Office Community Outreach and Media Relations have been carbon copied in this email and can be contacted at (916) 843-3310.
If you have any questions or require additional assistance pertaining to your California Public Records Act request, please contact any member of the Public Records Unit at (916)843-4030.
Thank you,
Rachna Sharma
Associate Governmental Program Analyst
California Highway Patrol, Office of Risk Management
Public Records Unit (916) 843-4030
CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws, including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.
From: Bennett Cyphers
Hi,
Thanks so much for your help with this request! I really appreciate it.
Sincerely,
Bennett Cyphers
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