|Multi Request||Geolocation data providers|
|Submitted||July 7, 2021|
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To Whom It May Concern:
The Electronic Frontier Foundation (EFF) seeks records describing the relationship between your agency and third-party providers of geolocation data. In particular, we seek records related to:
• the location data provider Gravy Analytics and its subsidiary Venntel
• Babel Street’s service Locate X.
For the purposes of this request, the term “geolocation data” refers to GPS data acquired from cell phone apps, connected vehicles, or other connected 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, 2015 and the present:
- All contracts or written agreements between Office of the Attorney General - Kentucky, or consultants thereof, and Gravy Analytics, Venntel, or Babel Street;
- All presentations, marketing materials, or proposals by contractors, subcontractors, or consultants working with Office of the Attorney General - Kentucky relating to the use of geolocation data from Gravy Analytics, Venntel, or Babel Street;
- All technical documentation, guides, presentations, or policies describing access to, storage of, or use of geolocation data acquired from Gravy Analytics, Venntel, or Babel Street;
- All written communications, emails, and attachments between Office of the Attorney General - Kentucky and Gravy Analytics, Venntel, or Babel Street;
- All written communications, emails, and attachments between Office of the Attorney General - Kentucky and INRIX.
If your office or agency contracts with a company not named here for geolocation data, provision of the alternate organization and equivalent responsive materials would be greatly appreciated.
The requested documents will be made available to the general public. This request is being made in the public interest and is not being made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Investigative Researcher, Electronic Frontier Foundation
Dear Beryl Lipton:
This letter shall constitute the Office of the Attorney General’s response to your open records request pursuant to the Kentucky Open Records Act, KRS 61.870 to 61.884. We received your request on July 9, 2021.
Since June 29, 2021, only residents of the Commonwealth may request to inspect public records. Under KRS 61.878(10), a “resident” is (a) an individual residing in the Commonwealth; (b) a domestic business entity with a location in the Commonwealth; (c) a foreign business entity registered with the Kentucky Secretary of State; (d) an individual that is employed and works at a location within the Commonwealth; (e) an individual or business entity that owns real property within the Commonwealth; (f) an individual or business entity that has been authorized to act on behalf of an individual or business entity listed above; or (g) a news-gathering organization as defined in KRS 189.635(8)(b)1a. to e.
Thus, effective June 29, 2021, a person submitting a request to inspect public records must include with the request a statement that the person making the request is a resident of the Commonwealth. A public agency may deny a request to inspect records that does not include such a statement. See KRS 61.872(2). Therefore, the Office requests that you re-submit your request with a statement that you are a resident of the Commonwealth.
If you wish to appeal this decision, you may do so by filing a complaint with the Attorney General’s Office, Open Records/Open Meetings Division, The Capitol, 700 Capital Avenue, Suite 118, Frankfort, KY 40601, pursuant to KRS 61.880(2), or by filing an original civil action in the appropriate circuit court under KRS 61.882. If you first appeal to the Attorney General but are dissatisfied with the Attorney General’s decision, you may further appeal to circuit court pursuant to KRS 61.880(5).
Charles A. English
Assistant Attorney General | Office of Civil & Environmental Law
Office of the Kentucky Attorney General
700 Capital Avenue | Suite 118 | Frankfort, Kentucky 40601
(502) 696-5340 | Chaz.English@ky.gov<mailto:Chaz.English@ky.gov>
Follow the Attorney General’s Office @KYOAG [fblogo15] <facebook.com/kyoag> [twitter15] <twitter.com/kyoag>