Skip to Content

IAPP CIPT: Has Location Data Been Pseudonymized in the Track and Trace Health App?

Learn why location data collected by the track and trace health app during the virus pandemic should be pseudonymized to protect user privacy. Understand how precise location information can enable identification of specific users.

Table of Contents

Question

SCENARIO –
Please use the following to answer the next questions:

Your company is launching a new track and trace health app during the outbreak of a virus pandemic in the US. The developers claim the app is based on privacy by design because personal data collected was considered to ensure only necessary data is captured, users are presented with a privacy notice, and they are asked to give consent before data is shared. Users can update their consent after logging into an account, through a dedicated privacy and consent hub. This is accessible through the ‘Settings’ icon from any app page then clicking ‘My Preferences’, and selecting ‘Information Sharing and Consent’ where the following choices are displayed:

  • “I consent to receive notifications and infection alerts”;
  • “I consent to receive information on additional features or services and new products”;
  • “I consent to sharing only my risk result and location information for exposure and contact tracing purposes”;
  • “I consent to share my data for medical research purposes”; and
  • “I consent to share my data with healthcare providers affiliated to the company”.

For each choice, an ‘ON’ or ‘OFF’ tab is available The default setting is ‘ON’ for all. Users purchase a virus screening service for US$29.99 for themselves or others using the app. The virus screening service works as follows:

Step 1: A photo of the user’s face is taken

Step 2: The user measures their temperature and adds the reading in the app

Step 3: The user is asked to read sentences so that a voice analysis can detect symptoms

Step 4: The user is asked to answer questions on known symptoms

Step 5: The user can input information on family members (name, date of birth, citizenship, home address, phone number, email and relationship).

The results are displayed as one of the following risk status “Low”, “Medium” or “High”. If the user is deemed at “Medium” or “High” risk an alert may be sent to other users, and the user is invited to seek a medical consultation and diagnostic from a healthcare provider.

A user’s risk status also feeds a world map for contact tracing purposes, where users are able to check if they have been or are in close proximity of an infected person. If a user has come in contact with another individual classified as ‘medium’ or ‘high’ risk, an instant notification also alerts the user of this. The app collects location trails of every user to monitor locations visited by an infected individual. Location is collected using the phone’s GPS functionality, whether the app is in use or not however the exact location of the user is “blurred’ for privacy reasons. Users can only see on the map circles with a 12-feet radius (approximately 4 meters wide), which is double the recommended distance for social distancing.

The location data collected and displayed on the map should be changed for which of the following reasons?

A. The information does not allow users to know how close they are to an infected person
B. The radius used for location data exceeds official social distancing rules
C. The location data has not been pseudonymized
D. The location data is too precise

Answer

C. The location data has not been pseudonymized

Explanation

The location data collected and displayed on the map by the track and trace health app should be changed because the location data has not been pseudonymized (Option C).

Pseudonymization is a technique that replaces personally identifiable information fields within a data record by one or more artificial identifiers, or pseudonyms. The purpose is to render the data record less identifying and therefore reduce concerns with data sharing and data retention.

In the given scenario, while the app “blurs” the exact location of the user by showing circles with a 12-feet radius on the map rather than pinpoint locations, this does not qualify as true pseudonymization. The location data is still too precise and could potentially allow individual users to be identified based on their location history and movement patterns.

With the current approach, someone analyzing the location data may still be able to single out which specific user the location trail belongs to, especially if they have additional information about that user’s typical locations and routines. Proper pseudonymization would better protect user privacy by replacing location coordinates with an artificial identifier not directly tied to the user’s identity.

The other answer options are incorrect because:
A) Knowing the exact distance from an infected person is not necessary from a privacy perspective
B) Exceeding official distancing rules does not itself create a privacy issue
D) Making location data less precise through “blurring” is helpful for privacy but does not accomplish pseudonymization

To fully protect user privacy, the app should go a step further and pseudonymize the location data so that the data cannot be attributed to a specific user without additional information. This aligns with privacy by design principles which call for proactively embedding privacy into the design and architecture of IT systems and business practices.

IAPP CIPT certification exam assessment practice question and answer (Q&A) dump including multiple choice questions (MCQ) and objective type questions, with detail explanation and reference available free, helpful to pass the IAPP CIPT exam and earn IAPP CIPT certification.