Geolocation data providers (Virginia Attorney General)

Tom Nash filed this request on behalf of Beryl Lipton with the Virginia Attorney General of Virginia.
Multi Request Geolocation data providers
Submitted July 7, 2021
Est. Completion None
Status
Payment Required

Communications

From: Beryl Lipton

Subject: Virginia Freedom of Information Act Request: Geolocation data providers (Virginia Attorney General)

Portal

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 Virginia Attorney General, or consultants thereof, and Gravy Analytics, Venntel, or Babel Street;
- All presentations, marketing materials, or proposals by contractors, subcontractors, or consultants working with Virginia Attorney General 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 privacy policies, memoranda of understanding, data-sharing agreements, or terms of use applying to geolocation data acquired from Gravy Analytics, Venntel, or Babel Street;
- All written communications, emails, and attachments between Virginia Attorney General and Gravy Analytics, Venntel, or Babel Street;
- All written communications, emails, and attachments between Virginia Attorney General 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.

Sincerely,

Beryl Lipton
Investigative Researcher, Electronic Frontier Foundation
beryl.lipton@eff.org

From: Virginia Attorney General

Subject: Virginia Freedom of Information Act correspondence – received July 12, 2021

Portal

Dear Ms. Lipton:

Please see attached regarding your Virginia Freedom of Information Act correspondence – received July 12, 2021.

Sincerely,

Meaghan E. O'Brien
FOIA Officer
Office of the Attorney General
202 North 9th Street
Richmond, Virginia 23219
http://www.ag.virginia.gov
[cid:image001.jpg@01D77CD0.E388BCB0]<http://www.ag.virginia.gov/>
[cid:image002.jpg@01D77CD0.E388BCB0]<https://www.facebook.com/AGMarkHerring>[cid:image003.jpg@01D77CD0.E388BCB0]<https://twitter.com/AGMarkHerring>

From: Muckrock Staff

Subject: RE: Virginia Freedom of Information Act Request: Geolocation data providers (Virginia Attorney General)

Email

Hello,

Thank you for your help with this request. Apologies for any confusion, but there was an error in our original submission, and this request is being made by Beryl Lipton in collaboration with Tom Nash, a Virginia resident. Please see attached for his proof of citizenship.

Again, thank you for your help with this request, and please let us know if we need to submit a new request.

From: Virginia Attorney General

Subject: FOIA Response

Email

Please see the attached correspondence regarding your FOIA requests.

Thank you,
Kimber Soto

[Office of the Attorney General]
Kimber Soto | Outside Counsel Legal Billing Specialist
Office of the Attorney General
202 North 9th Street
Richmond, Virginia 23219
O: (804) 786-9787 | M: | F:
https://www.oag.state.va.us

[Office of the Attorney General]
FOIA |
Office of the Attorney General
202 North 9th Street
Richmond, Virginia 23219
O: | M: | F:
F3@oag.state.va.us<mailto:F3@oag.state.va.us>
https://www.oag.state.va.us

From: Muckrock Staff

Subject: RE: Virginia Freedom of Information Act Request: Geolocation data providers (Virginia Attorney General)

Fax

Hello,

Please see attached. Thank you for your help with this request!

From: Virginia Attorney General

Subject: FOIA Request

Email

Tom Nash
3122 Bute LN
Richmond, VA 23221
requests@muckrock.com

Re: Freedom of Information Act request - received December 22, 2023

Dear Tom Nash:

The Office of the Attorney General for the Commonwealth of Virginia ("Office") acknowledges receipt of the above-referenced correspondence in which you seek certain information contained in public records pursuant to the Virginia Freedom of Information Act, Virginia Code Section 2.2-3700, et seq. ("FOIA"). Specifically, you state:

we request the following records for the period between January 1, 2015 and the present:
- All contracts or written agreements between Virginia Attorney General, or consultants thereof, and Gravy Analytics, venntel, or Babel street;
- All presentations, marketing materials, or proposals by contractors, subcontractors, or consultants working with Virginia Attorney General 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 privacy policies, memoranda of understanding, data-sharing agreements, or terms of use applying to geolocation data acquired from Gravy Analytics, venntel, or Babel street;
- All written communications, emails, and attachments between Virginia Attorney General and Gravy Analytics, venntel, or Babel street;
- All written communications, emails, and attachments between Virginia Attorney General and INRIX.

Virginia Code Section 2.2-3704(H) provides that, where a public body determines in advance that charges for producing requested records are likely to exceed $200, the public body may require the requester to agree to payment of a deposit not to exceed the amount of the advance determination before continuing to process the request.

The universe of records responsive to your request will need to be identified, accessed, duplicated, reviewed line by line for potentially exempt material, and potentially redacted. A conservative estimate, based upon current knowledge regarding the potential universe of responsive documents and the presumed amount of employee time devoted to this endeavor, is that fulfillment of these portions of your requests will exceed $200. Please be advised that this cost estimate is provided with the caveat that we do not know the exact number, if any, of responsive documents and, accordingly, the actual amount of employee time expended in review may be greater than estimated. If it is greater than estimated, you will be charged accordingly; conversely, if it is lesser than estimated, you will receive a refund.

Given that this Office serves as the law firm of the Commonwealth, kindly note that the large amount of our records pertain to legal matters and therefore may be subject to various exemptions. Those items would not be produced.

The Supreme Court of Virginia held that a public body is permitted to charge for review of public records to assure that those records are responsive, non-exempt from disclosure, and may be disclosed without violating other provisions of law.[1] The grid below explains the charges in detail. Please be advised that the chart below does not include the cost of copies. Those costs cannot be estimated at this time, but may increase the estimate contained in the grid below. Further, employees not listed below may be required to search for and review responsive records that are in their possession. For these reasons, you may receive an additional invoice after your request is processed.

Classification
Hourly Rate
Approx. Hours
Total
Non-attorney staff
$29.15
8.8
$256.52

Grand Total:
$256.52

If you wish to proceed with your request as submitted, kindly remit a check payable to the Treasurer of Virginia for the grand total found in the table above. Your payment may be sent to the address below:

Office of the Attorney General
c/o FOIA Officer
202 North Ninth Street
Richmond, Virginia 23219

Once payment is received, this Office will commence with processing your request.

Tyler Barnes
Assistant General Counsel

________________________________

[1] See American Tradition Institute v. Rector and Visitors of the University of Virginia, 756 S.E.2d 435 (Va. 2014).

[Office of the Attorney General]
FOIA |
Office of the Attorney General
202 North 9th Street
Richmond, Virginia 23219
O: | M: | F:
F3@oag.state.va.us<mailto:F3@oag.state.va.us>
https://www.oag.state.va.us

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