Letter to FTC

Re: Consumer Privacy Protection Principles for Vehicle Technologies and Services

            On behalf of the Participating Members of the Alliance of Automobile Manufacturers, Inc. (“Alliance”) and the Association of Global Automakers (“Global Automakers”), we are submitting to you Consumer Privacy Protection Principles for Vehicle Technologies and Services.  The Participating Members are publicly committing to implement these Principles.

Starting in the Spring of 2014, Members of the Alliance and Global Automakers came together to create a set of privacy principles for vehicle technologies and services (“Principles”), to which members of the Associations and others can agree to as baseline privacy commitments.

The Principles reflect a major step in the protection of personal information collected through in–car technologies.  Although individual Members of both Associations have long protected the personal information under their control, the Principles mark the first industry–wide statement of privacy principles showing a commitment to responsible stewardship of the information used to provide vehicle technologies and services.  Sensitive information, like geolocation information and driver behavior information receives heightened protections.

The Principles reflect the reality that automobiles increasingly have innovative technologies and services designed to enhance vehicle safety, improve vehicle performance, and augment the driving experience, and that many of these technologies and services rely upon information collected from vehicle systems.  Sometimes, that information includes the precise location information of vehicles, or information about how drivers operate their vehicles.   This information, which is critical to safety and the driving experience, deserves protection.   

The Principles establish a framework that automakers and other participants in the automotive industry may choose to adopt when offering innovative vehicle technologies and services.  The Participating Members adopting this framework commit to seven Principles: Transparency; Choice; Respect for Context; Data Minimization, De-Identification & Retention; Data Security, Integrity & Access, and Accountability.  These Principles are based on the Fair Information Practice Principles (“FIPPs”), which have served for over forty years as the basis for privacy frameworks in the United States and around the world.

The establishment of these Principles complements another joint action by our two associations to help promote the security of vehicle–generated data.  In July of this year, the Alliance and Global Automakers committed to the U.S. Department of Transportation’s National Highway Traffic Safety Administration (“NHTSA”) to working towards the establishment of a voluntary automobile industry sector information sharing and analysis center (“ISAC”) or comparable program for collecting and sharing information about existing or potential cyber–related threats and vulnerabilities in motor vehicle electronics or associated in–vehicle networks (“Auto–ISAC”) that is appropriate to the needs and particular circumstances of the automobile industry sector.



Mitch Bainwol
President and Chief Executive Officer
Alliance of Automobile Manufacturers, Inc.

John Bozzella
President and Chief Executive Officer
Association of Global Automakers, Inc.

Download the Full Letter to the U.S. Federal Trade Commission