IN-CAR LOCATION- BASED SERVICES

Companies Are 

Taking Steps to 

Protect Privacy, but 

Some Risks May Not 

Be Clear to 

Consumers

Report to the Chairman, Subcommittee 

on Privacy, Technology and the Law, 

Committee on the Judiciary, U.S. 

Senate

December 2013

GAO-14-81

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-81, a report to the 

Chairman, Subcommittee on Privacy, 

Technology and the Law, Committee on the 

Judiciary, U.S. Senate

December 2013

IN-CAR LOCATION-BASED SERVICES

Companies Are Taking Steps to Protect Privacy, but 

Some Risks May Not Be Clear to Consumers

Why GAO Did This Study

The prevalence of in-car

communication systems provided by 

auto manufacturers (called telematics 

systems), PNDs, and smart phones 

has brought significant opportunities 

for consumers to access locationbased services in their cars. As in-car 

location-based services have become 

commonplace, privacy groups and 

policy makers have questioned 

whether location data collected by 

companies can be used for purposes 

beyond the provision of services, such 

as by data brokers who collect 

information to resell the information. 

GAO was asked to review this issue. 

This report addresses (1) what 

selected companies that provide in-car 

location-based services use location 

data for and if they share the data, and 

(2) how these companies’ policies and 

reported practices align with industryrecommended privacy practices. GAO 

selected a non-generalizable sample of 

10 companies. The companies were 

selected because they represent the 

largest U.S. market share or because 

their services are widely used. GAO 

examined documentation and 

interviewed representatives from each 

company regarding their privacy 

practices in effect in 2013 and 

compared those practices to industry 

recommended privacy practices. 

What GAO Recommends

Since this report examines private 

companies’ use of location data, GAO 

is not making recommendations to 

federal agencies. The Department of 

Commerce, Federal Trade 

Commission, and the selected 

companies provided technical 

comments, which GAO incorporated as 

appropriate.

What GAO Found

Representatives from all 10 selected companies—auto manufacturers, portable 

navigation device (PND) companies, and developers of map and navigation 

applications for mobile devices—said they collect location data to provide 

consumers with location-based services. For example, companies collect 

location data to provide turn-by-turn directions. Nine companies share location 

data with third-party companies, such as traffic information providers, to provide 

services to consumers. Representatives from two companies said they share 

data where personally identifiable information has been removed (de-identified 

data) for purposes beyond providing services (e.g., for research), although such 

purposes are not always disclosed to consumers. All company representatives 

said that they do not share personally identifiable location data with or sell such 

data to marketing companies or data brokers.

All 10 selected companies have taken steps consistent with some, but not all, 

industry-recommended privacy practices. In addition, the companies’ privacy 

practices were, in certain instances, unclear, which could make it difficult for 

consumers to understand the privacy risks that may exist. 

• Disclosures

•

: Consistent with recommended practices, all selected companies 

disclose that they collect and share location data. However, inconsistent with 

recommended practices, nine companies’ disclosures provide reasons for 

collecting data that are broadly worded (e.g., the stated reasons for collecting

location data were not exhaustive), and five companies’ disclosures do not 

describe the purposes for sharing de-identified location data. Without clear 

disclosures, risks increase that data may be collected or shared for purposes 

that the consumer is not expecting or might not have agreed to.

Consent and controls

•

: Consistent with recommended practices, all selected 

companies obtain consumer consent to collect location data and obtain this 

consent in various ways. In addition, all companies offered consumers some 

controls over location data collection. However, if companies retained data, 

they did not allow consumers to request that their data be deleted, which is a 

recommended practice. Without the ability to delete data, consumers are 

unable to prevent the use or retention of their data, should they wish to do 

so. 

Safeguards and retention

•

: All selected companies take steps to safeguard 

location data—a recommended practice—but use different de-identification 

methods that affect the extent to which consumers may be re-identified and 

exposed to privacy risks. Also, there is wide variation in how long companies 

retain vehicle-specific or personally identifiable location data. To the extent 

that a company’s de-identification methods allow a consumer to be identified 

or that identifiable data are retained, risks increase that location data may be 

used in ways consumers did not intend or may be vulnerable to unauthorized 

access.

Accountability: All selected companies disclose to consumers or take steps 

to protect location data that they share with third parties; such efforts are 

consistent with recommended practices. However, inconsistent with 

recommended practices, none of the selected companies disclose to 

consumers how they hold themselves and their employees accountable. The 

companies told GAO that internal company policies serve this function.

View GAO-14-81. For more information, 

contact Lori Rectanus at (202) 512-2834 or 

rectanusl@gao.gov.
Page i GAO-14-81 In-Car Location-Based Services

Letter 1

Background 4

Selected Companies Stated That They Primarily Collect and 

Share Location Data to Provide and Improve Consumer 

Services 9

Selected Companies Have Implemented Some Recommended 

Practices, but the Extent to Which Consumers’ Privacy Could 

Be at Risk May Not Be Clear 12

Agency Comments 21

Appendix I Objectives, Scope, and Methodology 23

Appendix II GAO Contact and Staff Acknowledgments 27

Tables

Table 1: Industry-Developed Recommended Privacy Practices 

Applicable to Location Data 6

Table 2: Select Laws That Address Consumer Privacy and Their 

Relevance to Privacy of Location Data 7

Table 3: Selected Companies That Provide In-Car Location-Based 

Services 23

Figures

Figure 1: Description and Examples of Systems or Devices That 

Deliver In-Car Location-Based Services to Consumers 4

Figure 2: How Location Data Are Transmitted to Provide In-Car 

Location-Based Services 5

Figure 3: Examples of De-Identification Methods and Privacy Risk 18

Contents
Page ii GAO-14-81 In-Car Location-Based Services

Abbreviations

Communications Act Communications Act of 1934

CPNI customer proprietary network information 

ECPA Electronic Communications Privacy Act of 1986 

FIPP Fair Information Practice Principles 

FTC Federal Trade Commission 

GPS Global Positioning Satellite 

NHTSA National Highway Transportation Safety

Administration 

NTIA National Telecommunications and Information

Administration 

PND portable navigation device

OECD Organisation for Economic Co-operation and

Development

VIN vehicle identification number

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Page 1 GAO-14-81 In-Car Location-Based Services

441 G St. N.W.

Washington, DC 20548

December 6, 2013

The Honorable Al Franken

Chairman

Subcommittee on Privacy, Technology and the Law

Committee on the Judiciary

United States Senate

Dear Mr. Chairman:

The prevalence of in-car communication systems (called “telematics”),1

as well as portable navigation devices (PND) and smart phones, has 

brought significant opportunities for consumers to access location-based 

services in their cars. Consumers increasingly use and benefit from these 

services not only for directions, but also for other services like real-time 

traffic information, emergency assistance, or to help find the nearest 

restaurant or gas station. The market for such location-based services is 

expected to grow as companies make use of new technologies, such as 

those that integrate smart phones with vehicles and those that use crowdsourced positioning, which uses location data gathered from a large 

number of consumers, to provide real-time traffic information. According 

to one study, for example, the market for telematics services provided by 

auto manufacturers in North America is expected to increase from 11.8 

million subscribers in 2012 to 31.6 million in 2016.2

As in-car location-based services have become commonplace, privacy 

groups and policy makers have questioned whether the location data 

collected and used by various companies in the course of providing such 

services pose privacy risks. Specifically, they are concerned that location 

data can be used for purposes other than to provide services to the 

consumer, such as selling the data to others for marketing. They also 

have concerns that location data can be used to track where consumers 

are, which can in turn be used to steal their identity, stalk them, or monitor 

 1

Telematics systems use telecommunication networks and GPS signals to allow 

information, such as location data, to be communicated between a car and a service 

provider.

2

Frost & Sullivan, Key Trends and Forecasts for the North American and Latin American 

Automotive Navigation and Telematics Services Market (May 2012).
Page 2 GAO-14-81 In-Car Location-Based Services

them without their knowledge. In addition, location data can be used to 

infer other sensitive information about individuals such as their religious 

affiliation or political activities. Congress and several federal agencies 

have considered the implications of the collection of location data on 

consumer privacy. While legislative proposals aimed at protecting the 

privacy of location data by mobile devices and navigation systems have 

been introduced by Members of Congress, none of the proposals have 

been enacted.3

You asked us to review issues related to the privacy of location data 

collected by in-car location-based services. This report addresses (1) 

what selected companies that provide in-car location-based services use 

location data for, and if the companies share the data and (2) how these 

companies’ policies and reported practices align with industryrecommended privacy practices. This work complements a review that we 

conducted on the privacy of location data collected by mobile devices. In 

that review, we found that the companies in our sample did not 

consistently follow industry-recommended privacy practices and that 

federal agencies could clarify their expectations for steps companies 

should take to protect consumers’ location data privacy. We 

recommended that the Federal Trade Commission (FTC) consider issuing 

guidance on protecting the privacy of location data and that the 

Department of Commerce’s National Telecommunications and 

Information Administration (NTIA) outline goals, milestones, and 

performance measures for its ongoing process to develop industry codes 

of conduct.4

To address our objectives, we selected 10 companies that provide 

services that rely on the real-time transmission of location data from a 

device in the car to a central location. The 10 selected companies include 

six auto manufacturers, two PND companies, and two map and 

 3

See Geolocational Privacy and Surveillance Act, H.R. 1312, 113th Cong. (2013); 

Geolocational Privacy and Surveillance Act, S. 639, 113th Cong. (2013). Additionally, a bill 

was introduced in the 112th Congress that addressed the privacy of location data. See 

Location Privacy Protection Act of 2012, S. 1223, 112th Cong. (2011).

4

GAO, Mobile Device Location Data: Additional Federal Actions Could Help Protect 

Consumer Privacy, GAO-12-903 (Washington, D.C.: Sept. 11, 2012). The report’s 

recommendation to FTC has been implemented. NTIA did not agree with our 

recommendation.
Page 3 GAO-14-81 In-Car Location-Based Services

navigation application (app) developers for mobile devices.5

We conducted this performance audit from February 2013 to December 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

While our 

findings are not generalizable to all companies that provide in-car 

location-based services, we selected auto manufacturers and PND 

companies that are the largest in the United States by market share and 

app developers that have widely used map and navigation apps on 

mobile devices. For example, the six auto manufacturers we selected 

constituted nearly 75 percent of new car sales in the United States in 

2012. For each company, we examined documentation of the company’s 

privacy practices in effect in 2013, which could include their privacy 

policies, terms of service agreements, and written disclosures to 

consumers, among other things. We further interviewed representatives 

from each of the companies to discuss its practices, as well as 

representatives from three third-party partners or contractors used by 

these companies to provide services, where applicable. While the 10 

companies in our review may use a number of third-party companies to 

provide services, we selected three third-party companies to interview 

because they specifically provide telematics or traffic-information 

services. The findings from these third parties are not generalizable to all 

third parties that provide location-based services, but provided us with 

insights about third-party use of location data. We reviewed documents 

and interviewed officials from the FTC, which protects consumers against 

unfair or deceptive business practices, including privacy issues, and 

NTIA, which advises the President on telecommunications and 

information policy issues. We also interviewed privacy advocates and 

automobile industry associations for their views on privacy practices and 

potential privacy risks that consumers might experience if companies do 

not implement the practices. See appendix I for a more detailed 

description of our scope and methodology.

 5

The selected auto manufacturers are Chrysler, Ford, General Motors, Honda, Nissan, 

and Toyota. The selected PND companies are Garmin and TomTom. The selected map 

and navigation application developers are Google Maps and Telenav. See appendix I for 

each of the companies’ location-based services that we focused on for this review. 
Page 4 GAO-14-81 In-Car Location-Based Services

In-car location-based services are delivered by telematics systems, 

PNDs, and map and navigation apps for mobile devices. See figure 1 for 

a description and examples of these systems and devices.

Figure 1: Description and Examples of Systems or Devices That Deliver In-Car Location-Based Services to Consumers

a

In cases where mobile devices are used, consumers use wireless technology to connect their mobile 

devices to their cars or PNDs. Once connected, consumers can access certain mobile device 

location-based services on the devices embedded in their cars or on their PNDs.

Telematics systems, PNDs, and map and navigation apps receive Global 

Positioning Satellite (GPS) signals, which identify the location of 

consumers in their cars. The consumers’ location data, which consist of 

GPS coordinates, are transmitted over the cellular network or Wi-Fi 

access points to companies providing the services. Based on the location 

information received, companies provide requested services to 

Background

In-Car Location-Based 

Services
Page 5 GAO-14-81 In-Car Location-Based Services

consumers. Companies may choose to partner with third parties to 

provide a specific location-based service, such as real-time traffic 

information. Companies may also choose to contract with third-parties 

that provide all location-based services on their behalf; among our 

selected companies, this is most common among the auto 

manufacturers.6

Figure 2: How Location Data Are Transmitted to Provide In-Car Location-Based Services

(See fig. 2.)

Note: While companies use cellular networks to transmit location data, we excluded 

telecommunications companies that provide these networks from this review because they were 

included in our 2012 report on mobile devices. See GAO-12-903.

The in-car location-based services industry continues to change and 

evolve: new partnerships are emerging in the marketplace, existing 

companies are changing how they provide location-based services, and 

 6

Some PNDs and navigation systems in cars are not equipped to transmit location data in 

real time to companies. These devices and systems are able to provide navigation 

assistance based on satellite or other signals received. However, these types of devices 

and systems are not within the scope of our review because they pose less privacy risks 

to consumers as compared to devices and systems that transmit location data to 

companies.
Page 6 GAO-14-81 In-Car Location-Based Services

technologies are advancing. For example, in 2012, a telecommunications 

company—Sprint—announced that it would partner with Chrysler to 

provide location-based and other in-car communication services using 

wireless technology embedded in cars. To expand its presence in the 

telematics and connected-service market, SiriusXM Radio Inc., a satellite 

radio broadcasting company, announced in 2013 that it entered into an 

agreement to acquire Agero Connected Services Inc., a company that 

auto manufacturers contract with to provide location-based services. In 

addition, some market analysts state that the market for stand-alone 

PNDs is waning, and as a result, existing PND companies have 

established partnerships with auto manufacturers to provide navigation 

services embedded in cars and have developed apps for mobile devices. 

Furthermore, as technologies that provide location-based services 

advance, auto manufacturers look to improve driver experiences by 

making cars more connected to mobile devices.

Mobile industry associations and privacy advocacy organizations have 

recommended practices that companies can take to better protect 

consumers’ privacy; we determined that these recommended practices 

can be applied to the companies discussed in this report.7

Table 1: Industry-Developed Recommended Privacy Practices Applicable to Location Data 

Specific 

examples of recommended practices are shown in table 1.

Category Examples of specific practices

Disclosures to consumers about data collection, 

use, and sharing

• State reasons companies collect and share data.

• State specifically that collection of location data is limited to specific needs.

• Do not use data for a purpose other than what has been disclosed to 

consumers without providing notice and obtaining consent before using the 

data.

Controls over location data • Obtain consumers’ consent before collecting their personal information.

• Provide consumers the ability to opt out of data collection to which they have 

previously consented.

• Allow consumers to delete location data that have been collected.

 7

We identified the recommended practices for our 2012 review on mobile device location 

data. See GAO-12-903 for examples of the recommended practices. Appendix I of this 

report contains more information about how we determined that the recommended 

practices could be applied to companies discussed in this report.

Industry Privacy Practices
Page 7 GAO-14-81 In-Car Location-Based Services

Category Examples of specific practices

Data safeguards and retention • State a specific time frame for retaining consumer data.

• Protect data with reasonable security safeguards against risks such as loss or 

unauthorized access.

Accountability • Ensure employees protect consumers’ data.

• Keep third parties responsible for protecting consumers’ data.

Source: GAO analysis of practices recommended by mobile industry associations and privacy advocacy organizations.

Currently, no comprehensive federal privacy law governs the collection, 

use, and sale of personal information by private-sector companies; rather,

the privacy of consumers’ data is addressed in various federal laws. 

Some of these federal laws are relevant to location data (see table 2).8

Table 2: Select Laws That Address Consumer Privacy and Their Relevance to Privacy of Location Data

The privacy of consumers’ location and other data is also protected in 

accordance with companies’ privacy practices. Federal law does not 

require companies to notify consumers of their privacy practices, but 

companies within the scope of our review have conveyed these practices 

through privacy policies and other documents. Additionally, FTC has 

reported that because protecting privacy is important to consumers, 

companies that deal with consumer data, including location data, have 

placed emphasis and resources on maintaining reasonable security.

Law Description 

Relevance to the privacy of location 

data

Federal Trade Commission 

(FTC) Act 

This Act prohibits unfair or deceptive acts or practices in or 

affecting commerce and authorizes FTC enforcement action. 

This authority allows FTC to take remedial action against a 

company that engages in a practice that FTC has found is 

unfair or deceives its customers. 

FTC could take action against a 

company if FTC found the company was 

being unfair or deceptive by not adhering 

to the company’s own privacy policies 

that describe how location data are 

collected, used and shared. 

 8

We reviewed select federal laws that are relevant to companies that provide in-car 

location-based services. We previously reported on a number of other federal privacy 

laws which were not relevant to our review. See GAO, Information Resellers: Consumer 

Privacy Framework Needs to Reflect Changes in Technology and the Marketplace, GAO13-663 (Washington, D.C.: Sept. 25, 2013).

Existing and Proposed 

Privacy Protections
Page 8 GAO-14-81 In-Car Location-Based Services

Law Description 

Relevance to the privacy of location 

data

The Communications Act of 

1934 (Communications Act) 

This Act, as amended, imposes a duty on 

telecommunications carriers to secure information and 

imposes particular requirements for protecting information 

identified as customer proprietary network information 

(CPNI), including the location of customers when they make 

calls. The Act also requires express authorization for access 

to or sharing of call location information concerning the user 

of commercial mobile services, subject to certain exceptions. 

The Act covers location data collected by 

telecommunications carriers, not location 

data collected by companies that provide 

in-car location-based services. 

Electronic Communications 

Privacy Act of 1986 (ECPA)

This Act prohibits the federal government and providers of 

electronic communications from accessing and sharing the 

content of consumers’ electronic communications, unless 

approved by a court or by consumer consent. The Act also 

prohibits providers of electronic communications from 

voluntarily disclosing customer records to government 

entities, with certain exceptions, but companies may disclose 

such records to a person other than a governmental entity.

The Act does not specifically address 

whether location data are considered 

content or part of consumers’ records. 

Some privacy groups have stated that 

ECPA should specifically address the 

protection of location data. 

Source: GAO summary and analysis of select laws.

Some privacy groups, some Members of Congress, and others maintain 

that privacy rights are being compromised by new uses of technology that 

are not addressed in existing laws. In 2012, FTC and NTIA called on 

Congress to pass data privacy legislation that would provide a minimum 

level of protection for consumer data, including location data. Some 

Members of Congress have introduced bills that would address the 

privacy of consumers’ electronic personal data, including location data. In 

particular, three of these bills would generally require commercial 

entities—such as those companies within the scope of this report—to 

provide notice and obtain consent from consumers to collect and share 

their location data.9

NTIA and FTC have both issued reports that offered recommendations 

aimed at improving overall consumer privacy, including location-based 

services. In February 2012, NTIA prepared a report for the White House 

that offered a framework and expectations for companies that use 

consumers’ personal information, which includes location information.10

 9

See H.R. 1312, 113th Cong. (2013); S. 639, 113th Cong. (2013). Additionally, a bill was 

introduced in the 112th Congress that addressed the privacy of location data. See S. 

1223, 112th Cong. (2011).

10The White House, Consumer Data Privacy in a Networked World: A Framework for 

Protecting Privacy and Promoting Innovation in the Global Digital Economy (Washington, 

D.C.: Feb. 23, 2012).
Page 9 GAO-14-81 In-Car Location-Based Services

The framework includes a consumer privacy bill of rights that states that 

consumers are entitled to, among other things, exercise control over what 

personal information companies collect and how they use it, and to easily 

understand and access information about companies’ data privacy and 

security practices. In March 2012, FTC issued a report that described 

recommended practices for companies that collect and use consumer 

data.11 This report recommended, for example, that companies obtain 

affirmative express consent from consumers before collecting precise 

location data; limit collection to data needed for a requested service or 

transaction; and provide consumers with prominent notice about the 

sharing of their location data. Companies’ use of NTIA’s and FTC’s 

practices for protecting consumers’ data is voluntary. Like the industrydeveloped recommended location data privacy practices described in 

table 1, the recommendations offered by NTIA and FTC are consistent 

with the internationally recognized privacy practices called the Fair 

Information Practice Principles (FIPP).

12

Representatives from all of the selected companies told us that they 

collect location data primarily to provide consumers with various 

requested location-based services. Telematics systems provided by the 

auto manufacturers we reviewed collect location data to respond to 

specific requests from consumers for location-based services such as 

turn-by-turn directions, information on local fuel prices, stolen vehicle 

tracking, or roadside assistance. Additionally, representatives from three 

auto manufacturers told us that their electric vehicle telematics systems 

use location data to help drivers of electric vehicles locate nearby 

charging stations. Separately, representatives from five auto 

manufacturers told us that their telematics systems also collect location 

data for other purposes. For example, a representative from one auto 

manufacturer told us that when a vehicle’s diagnostic trouble code is 

displayed (e.g., the check engine indicator light is displayed) or during 

monthly checks by the telematics system, the company collects location 

 11Federal Trade Commission, Protecting Consumer Privacy in an Era of Rapid Change: 

Recommendations for Businesses and Policymakers (Washington, D.C.: March 2012).

12We used the industry-developed privacy practices—not the NTIA and FTC 

recommended practices—to evaluate our 10 selected companies’ reported privacy 

practices because the industry-developed privacy practices are specific to location data. 

NTIA’s and FTC’s recommended practices address consumer data, which include but are 

not specific to location data.

Selected Companies 

Stated That They 

Primarily Collect and 

Share Location Data 

to Provide and 

Improve Consumer 

Services
Page 10 GAO-14-81 In-Car Location-Based Services

data along with vehicle data to determine whether driving in certain 

locations, such as near power plants, affects a vehicle’s overall 

performance. The companies we reviewed that sell PNDs and navigation 

apps for mobile devices similarly collect location data to provide 

consumers with requested traffic and navigation services. Some of these 

companies may also collect location data to provide consumers additional 

features such as the location of nearby restaurants or points of interest.

Representatives from all 10 selected companies told us that they share 

consumer location data with third parties to provide and improve services, 

with law enforcement, or with others for other purposes when data are deidentified.13

• Sharing to provide and improve services: Representatives from nine 

of the selected companies told us that they share location data to 

provide location-based services to consumers or to improve the 

accuracy of services provided to consumers; representatives from the 

remaining company said that it does not share location data of 

consumers using its traffic and navigation services because it 

provides these services in-house. The six selected auto 

manufacturers generally share location data with third parties that 

provide consumers with location-based services. For example, of 

these auto manufacturers, three authorize the same third-party 

contractor to collect and use vehicle-specific location data to provide 

telematics services on the auto manufacturers’ behalf. Although the 

level of services varies by manufacturer, this third-party company 

provides services to consumers such as navigation assistance, traffic 

assistance, and concierge services where consumers can obtain 

assistance from live operators for business and personal needs such 

 13“De-identified” location data are those data that have had personally identifiable 

information, such as a consumer’s name or home address, removed or masked. When 

data are de-identified, a consumer’s personally identifiable information could be 

reconstituted in certain circumstances (that is, the consumer can be re-identified). If 

location data are de-identified in a way that a consumer cannot be re-identified, then the 

data are anonymous. Aggregating de-identified data, which combines de-identified data 

from a number of individuals or vehicles, are anonymous because the data cannot be 

linked to an individual at all. Aggregated vehicle location data could be used, for example, 

to determine the speed of vehicles at 5 p.m. on a certain section of a road. The deidentification methods companies use may or may not result in location data that are 

anonymous. For more information on de-identified, anonymous, and aggregated data, see 

National Institute of Standards and Technology, Guide to Protecting the Confidentiality of 

Personally Identifiable Information (PII), Special Publication 800-122 (Gaithersburg, 

Maryland: April 2010). 
Page 11 GAO-14-81 In-Car Location-Based Services

as making flight or restaurant reservations. Auto manufacturers’ 

telematics systems may also share vehicle-specific location data with 

public-safety emergency-service providers and third-party roadside 

assistance providers so that they can provide emergency and 

breakdown assistance. Representatives from both PND companies 

and one app developer said that they share aggregated location data 

associated with traffic flows with third parties, including traffic 

information providers. Traffic information providers use such data, 

along with data from various other sources (such as traffic alerts and 

GPS data collected from vehicle fleets) to augment and improve the 

accuracy of real-time traffic services provided to consumers.

• Sharing with law enforcement: All 10 of the selected companies’ 

disclosures describe circumstances under which they may share 

location data with law enforcement. For example, one company’s 

disclosure states that the company can, when required, share location 

data “to comply with the law, in legal proceedings, to respond to 

subpoenas or court orders, and in cooperation with law enforcement 

agencies.” Another company’s disclosure states that it is not required 

to release any records that are created as part of its service without a 

subpoena (unless otherwise required by law). However, for 

companies that do not retain personally identifiable location data, 

there are no data for law enforcement to use.

• Sharing for other purposes: Representatives from two of the selected 

companies told us that they share location data for other purposes 

beyond providing services to consumers. Representatives from these 

two companies told us that they have provided location data that they 

have de-identified or aggregated to university research programs, the 

National Highway Transportation Safety Administration (NHTSA), and 

state departments of transportation for research purposes (e.g., 

causes of accidents) and to improve information about traffic patterns 

for infrastructure planning.14

 14Specifically, representatives from one company told us that it shares location data that 

are associated with unique vehicle identifiers or location data that are aggregated. The 

other company shares location data that have been de-identified and aggregated. 

Representatives from both companies 

told us that they have contractual agreements in place with these 

entities that govern how the data should be used and protected. 

Separately, representatives from all of the selected companies told us 

that they do not share identifiable location data with or sell such data 

to marketing companies or data brokers that collect information for the 

purposes of reselling the information to others. However, 
Page 12 GAO-14-81 In-Car Location-Based Services

representatives from one of these companies told us that it shares 

aggregated data with marketing companies.

As discussed in more detail below, while the companies we reviewed 

stated that they did not share data for purposes other than those 

mentioned, their policies give them the flexibility to do so. In addition, 

some companies do not describe the purposes for sharing de-identified 

location data in their disclosures to consumers. Furthermore, as we 

discuss later in this report, companies use various methods to de-identify 

location data, some of which could result in a consumer being reidentified (that is, their personally identifiable information could be 

reconstituted).

Industry-recommended practices state that companies should protect the 

privacy of location data by providing (1) disclosures to consumers about 

data collection, use, and sharing; (2) controls over location data; (3) data 

safeguards and explanations of retention practices; and (4) accountability 

for protecting consumers’ data. The recommended practices are not 

required, but rather provide a framework for understanding the extent to 

which these companies protect the privacy of consumers’ location data. 

We found that all 10 companies have taken steps that are consistent with 

some, but not all, of the recommended practices, and the extent to which 

consumers’ data could be at risk may not be clear to consumers.

Recommended practices state that companies should clearly disclose 

how they collect, use, and share location data and the purposes for doing 

so. We found that companies use various methods to disclose their 

privacy practices, but the information about the use and sharing of 

location data was sometimes unclear. Without clear disclosures about the 

collection and sharing of location data, consumers may not be aware of 

all the purposes for which their data are collected and shared. Thus, data 

may be used and shared for purposes that the consumer is not expecting 

or to which the consumer might not have chosen to agree. Privacy 

advocates as well as the FTC and NTIA have stated that privacy 

disclosures should be clearly written, readily available, and describe all 

purposes for which personal data are collected and shared.

All 10 selected companies use privacy policies, terms of service 

agreements, and other practices—such as on-screen notifications—to 

notify consumers of their privacy practices. Of the 10 companies we 

Selected Companies 

Have Implemented 

Some Recommended 

Practices, but the 

Extent to Which 

Consumers’ Privacy 

Could Be at Risk May 

Not Be Clear

Selected Companies 

Disclose That They Collect 

and Share Location Data, 

but Disclosures to 

Consumers Are 

Sometimes Unclear

Notification Methods
Page 13 GAO-14-81 In-Car Location-Based Services

reviewed, six have stand-alone privacy policies and four use terms of 

service agreements that include an explanation of their privacy practices. 

Of the six companies that have stand-alone privacy policies, four 

companies and one of the auto manufacturers for its electric vehicle 

provide notice via an on-screen display. According to one auto 

manufacturer, its services are requested and provided through voice 

command and audible response rather than through a screen, making onscreen notifications impractical with current systems. Further, the nature 

of the service makes it difficult and inconvenient to notify consumers 

about location data collection each time service is requested. For 

example, the auto manufacturer said that it would not be practical for 

notification to occur in connection with the delivery of emergency services 

since those tend to be provided automatically, without consumer request, 

when there is an accident.

All 10 selected companies disclose the reasons for collecting location 

data, which are generally based on the types of services they provide. 

However, 9 of 10 companies also provide reasons for collecting location 

data that are broadly worded and potentially allow for unlimited data 

collection and use. For example, one company’s terms of service states 

that the provided reasons for location data collection were not exhaustive. 

Furthermore, none of the selected companies explicitly state in their 

disclosures that location data are not collected for other purposes. Three 

of the selected companies state in their disclosures that they seek 

consumers’ consent before using location data for purposes beyond 

those listed. Without clear disclosures about the purposes, consumers 

may not able to effectively judge whether the uses of their location data 

might violate their privacy. Furthermore, risks increase that data may be 

used for purposes the consumer is not expecting or to which the 

consumer might not have chosen to agree.

All 10 selected companies disclose that they share consumer location 

data with third parties, mainly to provide requested services. Six 

companies’ disclosures allow for additional sharing for location data when 

they are de-identified, but the purposes for sharing such data were not 

described in five of these companies’ disclosures. Although not disclosed, 

representatives from three of the five companies explained to us that they 

share de-identified or aggregated location data for providing services or 

for other purposes. Representatives from the remaining two companies 

said that although their disclosures give them the option to share deidentified location data, their companies do not share such location data 

at all. Because companies have not made clear disclosures about the 

purposes for sharing de-identified location data, risks increase that data 

Purposes for Collection and 

Use

Purposes for Sharing Location 

Data
Page 14 GAO-14-81 In-Car Location-Based Services

may be used for purposes that the consumer is not expecting or to which 

a consumer might not have chosen to agree.

Recommended practices state that companies should obtain consumers’ 

consent for collecting, using, and sharing personal information, including 

location data, and allow consumers to control their data, such as by 

opting-in and opting-out of collection and deleting location data. We found 

that companies obtain consumer consent and provide controls in a variety 

of ways, but do not allow consumers to request their historical location 

data to be deleted when data are associated with an individual or vehicle. 

Without the ability to delete their location data, consumers are unable to 

prevent the use or retention of their data, should they wish to do so. 

Privacy advocates, as well as the NTIA and FTC, have stated that 

consumers should provide their consent and have an appropriate level of 

control over how their personal data are collected, used, and shared. 

NTIA and privacy advocates have also stated that consumers should be 

able to request deletion of data collected about them.

The selected companies obtain consumer consent to collect location data 

in various ways, but some methods are more explicit than others. For 

example, auto manufacturers obtain consumer consent when consumers 

agree to the terms of service either when purchasing the vehicle 

equipped with the service or when signing-up and paying for the service. 

According to one privacy group we met with, if consent is obtained when 

a consumer purchases a vehicle, consumers may not be as likely to 

review a company’s stated privacy practices because they may be a part 

of a larger set of documentation about the vehicle and its telematics 

system. Both PND companies and one auto manufacturer (for its electric 

vehicle) obtain consumer consent to collect location data more explicitly, 

via an on-screen prompt that allows consumers to accept or decline the 

transmission of such data. Both of the selected app developers we 

reviewed obtain consumer consent when consumers agree to the terms 

of the privacy policy or the terms of service (which includes a developer’s 

privacy policy) when initially downloading the app.

The selected companies provide consumers various ways to opt in or out 

of location data collection. For example, auto manufacturers provide 

consumers with controls over location data collection by offering the 

telematics system as an option on a new vehicle purchase. However, 

auto manufacturers are including these systems as standard equipment 

on vehicles. In fact, one auto manufacturer told us it now provides a 

limited-time free subscription to its telematics service on most of its new 

cars, but that consumers can cancel at any time. According to the 

Selected Companies 

Obtain Consent and 

Provide Certain Controls 

for Collecting Location 

Data, but Consumers Are 

Not Able to Delete Their 

Collected Data

Consent

Controls
Page 15 GAO-14-81 In-Car Location-Based Services

company, once a consumer cancels the subscription, location data are 

not collected, despite the equipment still being in the vehicle. Additionally, 

auto manufacturers told us that consumers can further choose to use 

these services or not. That is, a consumer has the option to request the 

location-based service and have location data transmitted, can refrain 

from using the service, or can cancel the service entirely.

Both selected PND companies allow consumers to decide if they want 

their location data transmitted. For one PND company, consumers can 

opt in to the collection and sharing of location data for traffic information 

purposes via an on-screen prompt. Consumers who do not opt in will not 

receive traffic data but they can still use other location-based services, 

such as weather, if they choose to do so. For the other PND company, 

consumers can control the collection of all location data via an on-screen 

prompt or by adjusting the device’s settings. If location data are turned 

off, consumers can still use the device for basic navigation but can no 

longer receive real-time traffic information. For the mobile device apps, 

consumers opt in to transmitting location data by downloading the app 

and requesting location-based services, and have the ability to opt out by 

not requesting services, changing the device’s setting to prevent location 

data from being transmitted, or deleting the app entirely. When 

consumers download one particular app, the app asks whether it can 

collect anonymous location data at any time, including when not providing 

a specific navigation service. In this case, the default is to collect the 

anonymous location data unless the consumer takes an additional step to 

opt out. The app developer seeks to collect such data to improve its 

traffic-information and other services. The consumer can also adjust the 

device’s settings at any time to prohibit the app from collecting the 

anonymous location data.

None of the 10 selected companies allow consumers to delete the 

location data that are, or have been, collected. Some companies deidentify and aggregate location data or do not retain any location data so 

it would not be possible for consumers to delete or request that their data 

be deleted. However, representatives from four companies told us that 

they keep the location data in a format that is associated with an 

individual vehicle yet do not allow consumers to delete their data or 

request their deletion. In such cases, consumers are unable to prevent 

the retention or use of retained data, should they wish to do so.

Deletion of Data
Page 16 GAO-14-81 In-Car Location-Based Services

Recommended practices state that companies should safeguard location 

data, in part, by de-identifying them; that companies should not keep 

location data longer than needed; and that such data should be deleted 

after a specific amount of time. We found that while selected companies 

safeguard location data in part by de-identifying them, companies use 

different de-identification methods that may lead to varying levels of 

protection for consumers. We also found wide variation in how long 

companies retain vehicle-specific or personally identifiable location data. 

Privacy groups we interviewed raised concerns about retaining location 

data for long periods of time because there are more opportunities to use 

the data to identify individuals or their behaviors and because longer 

retention periods put data at increased risk for unauthorized access or 

accidental disclosure. In addition, privacy groups said that de-identifying 

location data may not always protect consumers against privacy risks 

because some methods of de-identification can allow for an individual to 

be re-identified.

All of the selected companies stated in their disclosures, or in interviews 

with us, that they use or share de-identified location data. 

Representatives from some of the selected companies explained how 

they de-identify location data; the methods differed among the companies 

that responded, for example:

• A representative from one app developer told us that for its map and 

navigation application, the company does not associate location data 

with consumers, unless the consumers have signed into their 

accounts. In addition, this company uses other methods to further 

reduce the likelihood that individuals (who have not signed into their 

accounts) will be indentified, such as collecting location data 

periodically rather than continuously.

• Representatives from four companies told us that they de-identify 

location data by removing consumers’ names from the location data, 

and associating the data with unique identification numbers. Three of 

these companies authorize their third-party contractor to collect 

location data along with a unique vehicle identification number or VIN

that all vehicles possess. This third party associates the VIN with 

other information to determine which vehicle to provide location-based 

services to. Representatives from the fourth company told us that 

before they share data for research purposes, they associate location 

data with unique vehicle identifiers or aggregate them.

• Representatives from three companies told us that they de-identify 

location data they receive from consumers (after consumers provide 

their consent) by associating the location data with randomly 

Selected Companies 

Stated That They DeIdentify Location Data, but 

Different Methods and 

Retention Practices May 

Lead to Varying Levels of 

Protection for Consumers

Safeguarding Location Data: 

De-Identification and 

Encryption
Page 17 GAO-14-81 In-Car Location-Based Services

generated identification numbers that change after a specific period of 

time.

• Representatives from three companies told us that before they share 

any location data with third parties, they strip the data of any 

identifiers and aggregate the data so that they are not tied to and not 

able to be tied to any particular consumer.

The de-identification method a company uses affects the extent to which 

consumers may be re-identified and exposed to privacy risks. Location 

data that are collected along with a consumer’s name or other identifying 

information are, by definition, personally identifiable data and present the 

greatest privacy risks to consumers because a consumer’s identity is 

known. Privacy risks decrease when companies de-identify location data, 

but the level of risk falls on a spectrum depending on how easy it is to reidentify consumers. De-identifying location data with unique identification 

numbers prevents the direct association of location data with a specific 

vehicle or individual. However, if the same identification number is reused for the same consumer on multiple trips, then the consumer’s 

history or patterns can potentially be discerned. In such instances, 

consumers face an increased likelihood that they can be re-identified. 

Privacy risks decrease if location data are associated with identification 

numbers that change over time because it is more difficult to discern an 

individual’s history and identify an individual. Finally, consumers face little 

to no privacy risks when location data are stripped of any identification 

numbers and aggregated with other consumers’ data because the data 

are anonymous, meaning that the data cannot be linked to an individual 

at all. (See fig. 3.) To the extent that companies use personally 

identifiable location data or use de-identification methods that allow a 

consumer to be re-identified, risks increase that consumer location data 

may be used in ways the consumer did not intend, such as to track their 

travel patterns or to target consumers for unwanted marketing 

solicitations.
Page 18 GAO-14-81 In-Car Location-Based Services

Figure 3: Examples of De-Identification Methods and Privacy Risk

Although location data that are coupled with personal information, such 

as a name, pose the greatest privacy risk to consumers, company 

representatives told us that in some cases, they need such data to 

provide certain services. For example, one auto manufacturer we met 

with said that one of its services—concierge services—is personalized to 

the consumer requesting the service and therefore relies on data that are 

associated with the individual requesting the services. Representatives 

from one third-party contractor that works with auto manufacturers said 

that consumers can receive a broader array of services by voluntarily 

providing additional data to service providers in connection with 

enrollment in the services. In contrast, representatives from PND 

companies and app developers told us that they do not need to know 

personally-identifiable information about a consumer to provide traffic and 

navigation services, just their location. As such, they said that their 

companies collect de-identified location data.

In addition to de-identifying location data, all of the selected companies 

stated in their disclosures, or in interviews with us, that they safeguard 

location data or personal data that may include location data. Eight 

companies’ disclosures state that they implement physical, technical, or 

other safeguards and the remaining two told us they have these 
Page 19 GAO-14-81 In-Car Location-Based Services

safeguards but did not state that they have them in any of their 

disclosures. Companies can safeguard location data by encrypting15

None of the selected companies’ disclosures discuss how long data are 

retained, but some company representatives we interviewed told us that 

that they do not retain location data “longer than necessary.” A 

contractor that works with three companies in our review to provide 

location-based services told us that when a consumer requests services, 

in accordance with the contractual terms in place with the companies, the 

contractor may retain vehicle-specific location data, VIN, and other data 

associated with the consumer’s request for up to 7 years. The contractor 

explained that it retains such subscriber information to protect against 

potential lawsuits, to allow the companies to evaluate how the contractor 

is performing, and for tax purposes should a tax authority audit their 

income associated with the provision of services. Representatives from 

one company stated that it retains personally identifiable location data for 

no more than 24 hours, and a representative from another company said 

that it does not retain such data at all. However, representatives from 

both of these companies told us that they retain de-identified location data 

indefinitely.

them 

while they are being transmitted between a vehicle or device and the 

company that provides location-based services. In our analysis of data 

transmitted from two selected mobile apps to the developers who provide 

location-based services, we found that one developer encrypted all data 

transmitted from the app, so we could not discern what was being 

transmitted. The other developer did not encrypt the data transmission, 

and we were able to view the location data and other data, such as 

usernames and passwords, being transmitted. This developer 

acknowledged that such data were not encrypted and told us that it had 

made a decision independent from our review to encrypt the data in future 

releases of the app. To the extent that data are not encrypted, consumers 

may be at risk that their data may be subject to unauthorized access, 

disclosure, and modification.

16 As we concluded in our 2012 report,17

 15Encryption protects data through a process of transforming ordinary data (commonly 

referred to as plaintext) into code form (ciphertext) so that the data are unintelligible to 

users without the proper decryption key.

the longer identifiable 

16Representatives from one of the companies told us that the data it retains are 

aggregated location data, and representatives from the other company told us that the 

data it retains are location data associated with unique identification numbers that change. 

17GAO-12-903.

Retaining Location Data
Page 20 GAO-14-81 In-Car Location-Based Services

location data are retained, the more vulnerable the data are to use by bad 

actors, such as hackers, or to unauthorized third-party access. 

Furthermore, risks increase that the amassed data could be used to 

create a detailed profile of individual behavior.

Recommended practices state that companies should demonstrate 

accountability for their practices as well as the practices for third parties 

they use to provide services. If accountability practices are disclosed to 

consumers, then consumers may have greater assurance that their 

location data are reasonably protected. We found that most of the 

selected companies disclose to consumers that they hold third parties 

accountable for safeguarding data that are shared. However, none of the 

companies disclose to consumers how they hold themselves and their 

employees accountable to their privacy policies, although company 

representatives told us they are taking steps to ensure that they and their 

employees are protecting consumers’ data and following their own 

privacy policies. Privacy groups and NTIA officials have stated that it is 

important for consumers to be assured that their location data are 

appropriately used and protected. To the extent that companies do not 

disclose the ways in which they hold themselves or third parties 

accountable, consumers will not be aware of how companies ensure that 

their data are appropriately protected.

All companies that share location data with third parties stated in their 

disclosures, or in interviews with us, that they take steps to protect 

location data that they share with third parties. For example, seven 

selected companies’ disclosures or company representatives stated that 

third parties are contractually required to follow the companies’ privacy 

policy or follow certain privacy practices. One of these companies has a 

business agreement with a third-party contractor that prohibits the 

contractor from collecting, using, and commingling data, including location 

data, about consumers or their behaviors for marketing purposes. In 

addition to holding third parties accountable through contracts, another 

company told us that in certain circumstances, it requires its third parties 

to conduct assessments to ensure that they are effectively protecting 

location data. Rather than conduct an assessment, some third parties 

choose to obtain certifications from professional security organizations. 

Separately, representatives from three companies told us that they 

protect location data that they share with third parties by de-identifying 

and aggregating them before they are shared.

Selected Companies Have 

Taken Steps to Be 

Accountable for Protecting 

Location Data, but the 

Steps They Take within 

Their Companies Are 

Generally Not Disclosed to 

Consumers

Accountability with Third-Party 

Service Providers
Page 21 GAO-14-81 In-Car Location-Based Services

None of the companies stated in their disclosures how they hold 

themselves and their employees accountable for adhering to their privacy 

policies; however, company representatives we interviewed explained 

various ways in which they ensure that they and their employees are 

protecting consumers’ data. Representatives from all of our selected 

companies told us that their employees must follow the companies’ 

internal polices to protect data, including location data, and some of the 

representatives further explained that employees who violate such 

policies are subject to disciplinary action and possibly termination. 

Separately, representatives from one of the selected companies told us 

that it had conducted an independent audit of its practices to provide 

reasonable assurance that it was in line with company privacy policies. 

For example, to assess whether the company followed its policy to 

encrypt location data and make them anonymous, the independent 

auditor assessed whether the company encrypted location data in a way 

that only the company could decrypt and that location data were 

anonymous so that individuals could not be identified and tracked.18

Our work provides information to policymakers on the various privacy 

risks consumers may face when companies collect and share location 

data to provide in-car location-based services. This information could be 

important to policymakers as they gauge whether privacy risks are 

appropriately balanced against the benefits that these services provide. 

Given that the report focuses on companies’ privacy practices, we are not 

making recommendations to federal agencies at this time.

While 

companies are taking actions to ensure that they are protecting 

consumers’ data, consumers may be unaware of these actions if they are 

not disclosed.

We provided drafts of this product to the Department of Commerce and 

FTC for comment. We also provided relevant portions of the draft to the 

10 selected companies and three third-party companies for comment. We 

received technical clarifications from both federal agencies, all 10 of the 

selected companies, and two of the three selected third-party companies. 

We incorporated these technical clarifications as appropriate.

 18The audit determined that the company effectively encrypted and de-identified the 

location data.

Accountability within a

Company

Agency Comments 
Page 22 GAO-14-81 In-Car Location-Based Services

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Secretary of 

Commerce and the Chairman of the FTC. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or rectanusl@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix II.

Sincerely yours,

Lori Rectanus

Acting Director, Physical Infrastructure
Appendix I: Objectives, Scope, and 

Methodology

Page 23 GAO-14-81 In-Car Location-Based Services

Our objectives were to examine (1) what selected companies that provide 

in-car location-based services use location data for and if they share it 

and (2) how these companies’ policies and reported practices align with 

industry-recommended privacy practices. This work complements a 

review that we conducted on the privacy of location data collected by 

mobile devices.1

To address these objectives, we examined the privacy practices of 

companies that provide in-car location-based services. We focused on 10 

companies that provide services that rely on the real-time transmission of 

location data from a car to a central location. These companies fall into 

three broad categories: (1) auto manufacturers, (2) portable navigation 

device (PND) companies,2

Table 3: Selected Companies That Provide In-Car Location-Based Services

and (3) map and navigation application (app) 

developers for mobile devices. We selected auto manufacturers and PND 

companies that are the largest in the United States by market share and 

app developers that have widely used map and navigation apps on 

mobile devices. See table 3. While our findings are not generalizable to 

all companies that provide in-car location-based services, the selected 

companies we reviewed are those that provide the most widely used 

services or represent a vast majority of the market. For example, the six 

auto manufacturers we selected represent nearly 75 percent of new car 

sales in the United States, and are therefore likely to have telematics 

systems that are more widely purchased by consumers.

Category Company Location-based service

Auto manufacturers Chrysler UConnect

Ford Sync

General Motors OnStar

Honda AcuraLink

Nissan Infiniti Connection, CARWINGS

Toyota Lexus Enform with Safety Connect, 

Toyota Entune

 1

GAO-12-903.

2

Some PNDs only receive GPS satellite signals and are not equipped to transmit location 

data to companies. These types of devices are not within the scope of our study because 

they do not transmit location data in real-time.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 24 GAO-14-81 In-Car Location-Based Services

Category Company Location-based service

PND companies Garmin Traffic

TomTom LIVE Services

Map and navigation 

application developersa Google Maps Navigation function

Telenav ScoutGPS Navigation

Source: GAO.

a

We also reviewed the policies and practices of Waze since it was one of the most popular apps, but 

during our review Waze was acquired by Google and was in the process of revising its policies and 

so declined to be interviewed for this report.

We identified privacy practices for the 10 companies within the scope of 

our review by interviewing representatives from these companies and 

reviewing their privacy policies and other documentation that described 

their privacy practices in effect in 2013, such as terms of service 

agreements with consumers and agreements with third parties about how 

data should be used. We also interviewed representatives of and 

reviewed documents from third-party service providers that some of these 

companies use. In particular we interviewed representatives and 

reviewed documents from Agero Connected Services, Inc; Inrix; and 

HERE (a Nokia company). While the 10 companies in our review may use 

a number of third-party companies to provide services, we selected three 

third-party companies to interview because they specifically provide 

telematics or traffic-information services. The findings from these third 

parties are not generalizable to all third parties that provide locationbased services, but provided us with insights about third-party use of 

location data.

To evaluate the 10 companies’ privacy practices, we compared them to 

practices recommended by privacy advocates and groups representing 

the mobile industry. We identified the recommended practices in our 2012 

report on mobile-device location data.3

 3

We determined that the 

recommended practices were applicable to companies providing in-car 

location-based services based on interviews with privacy advocacy 

groups and because our 2012 mobile device report found that the 

recommended practices generally aligned with the internationally 

recognized privacy practices called the Fair Information Practice

GAO-12-903.
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-14-81 In-Car Location-Based Services

Principles (FIPP).4

To better understand companies’ implementation of privacy practices and 

potential privacy risks

To conduct the evaluation, two analysts conducted 

separate analyses of the 10 companies’ privacy policies, other 

documentation on companies’ privacy efforts, and information gained 

from our interviews to determine how the companies’ practices compared 

to the recommended practices. Then, the two analysts obtained 

consensus on those determinations where there had not been 

agreement. In general, our evaluation examined the companies’ privacy 

practices as stated in their privacy policies, other documentation, or in 

their interviews with us. We did not independently determine the extent to 

which companies implemented reported privacy practices, but we 

corroborated them with our own observations of these services and 

information from third parties where possible. For example, we were able 

to observe the actual practices that two selected mobile applications used 

to protect data transmitted from the applications to the developers. 

Specifically, we used a computer program to log, monitor, and document 

all network activity between the two mobile applications and the 

developers’ servers.

5

 4

The FIPPs are widely accepted principles for protecting the privacy and security of 

personal information. They were first proposed in 1973 by a U.S. government advisory 

committee. FIPPs are not precise legal requirements. Rather, they provide a framework of 

principles for balancing the need for privacy with other interests. The Organisation for 

Economic Co-operation and Development (OECD), an international organization, 

developed a revised version of the FIPPs in 1980 that has been widely adopted. See 

that consumers might experience if companies do 

not implement the practices, we met with a number of groups or 

individuals who are knowledgeable about the privacy of location data. 

Specifically, we met with privacy advocates (Future of Privacy Forum, 

Electronic Privacy Information Center, American Civil Liberties Union, 

Electronic Frontier Foundation, Center for Democracy and Technology); a 

company that certifies businesses privacy programs (TRUSTe); and one 

privacy researcher (Dorothy Glancy). We also met with associations 

knowledgeable about the automotive industry or in-car location-based 

technologies (Alliance of Automobile Manufacturers, Global Automakers, 

Center for Automotive Research, and the Intelligent Transportation 

Society of America) to better understand the direction of the automotive 

GAO-12-903 for more information.

5

This review was not designed to identify whether there were any actual violations of 

consumers’ privacy.
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-14-81 In-Car Location-Based Services

industry and technologies. Although the information provided by these 

groups, individuals, and associations are not generalizeable, their views 

provided us with a perspective on the benefits and risks associated with 

location data use and sharing. In addition, we reviewed documents and 

interviewed officials from Federal Trade Commission and the Department 

of Commerce’s National Telecommunications and Information 

Administration. We also conducted a literature review on techniques to 

de-identify data.

We conducted this performance audit from February 2013 to December 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 27 GAO-14-81 In-Car Location-Based Services

Lori Rectanus, (202)-512-2834 or rectanusl@gao.gov

In addition to the contact named above, Andrew Von Ah (Assistant 

Director), Thomas Beall, Melissa Bodeau, Mark Canter, Michael 

Clements, Roshni Davé, Leia Dickerson, John de Ferrari, Andrew 

Huddleston, Terence Lam, Joshua Ormond, David Plocher, Paul G. 

Revesz, Nancy Santucci, and Crystal Wesco made key contributions to 

this report.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(543319)
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