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Privacy Guidelines for RFID Information Systems

By Ann Cavoukian, Ph.D.
September 18, 2006

Radio frequency identifier ('RFID') tags are the next evolution in technology from barcodes. Containing micro-chips and tiny radio antennas that can be attached to products, RFID tags can transmit a unique identifying number to an electronic reader, which in turn links to a computer database where information about the item is stored. To manufacturers, suppliers, and retailers, RFID tags can be valuable tools in managing inventory, but for consumers they can also pose a potential risk to privacy if linked to personal information. RFID tags are becoming more prevalent in our everyday lives from security access cards to ignition immobilizers to highway toll systems and other electronic pass systems. Further, the ubiquitous presence of RFID tags for consumer-level items is rapidly approaching. From cans of shaving cream to sweaters, RFID tags may soon be found on almost every product as companies look to optimize their inventory control and supply chain management practices. However, for RFID technology to fully realize its potential for consumers, retailers, and suppliers, it is vital that privacy concerns be addressed in the design and implementation of this emerging technology.

The Information and Privacy Commissioner of Ontario, Canada ('IPC') first identified the potential privacy concerns raised by RFID technology in 2003, in the IPC paper Tag, You're It: Privacy Implications of Radio Frequency Identification (RFID) Tech-nology. Since then, the technology has evolved considerably, so it is time to revisit the topic and specifically address privacy issues in the consumer space.

The IPC has a mandate to educate the public and address privacy questions raised by new information technologies, with a view toward encouraging effective solutions. Further, the Commissioner has always found it beneficial to assist those working on emerging technologies ' being proactive whenever possible ' to develop effective guidelines and codes before potential problems arise. Accordingly, in June 2006, the Commissioner developed IPC Privacy Guidelines for RFID Information Systems ('Guidelines') in collaboration with EPCglobal Canada, an industry association that sets standards for electronic products codes. These made-in-Canada Guidelines were developed to provide practical guidance and solutions regarding item-level consumer RFID applications and uses.

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