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78 Smartcard Interoperability Issues for the Transit Industry To determine if a smartcard fare payment system may be at risk of invading an individual's right to privacy, the system's data needs to be analyzed to determine the personal identifiable informa- tion that is collected in the normal course of business. If it is determined that an individual's right to privacy is at risk, then the Privacy Alliance (a group of more than 80 global corporations and associations who work together toward on-line privacy for individuals) recommends taking the following steps to minimize the exposure to potential litigation: Adopt and Implement a Privacy Policy--Any organization engaged in electronic-funds trans- fer has the responsibility to adopt and implement a policy to protect the privacy of personally identifiable information Adopt a Notice and Disclosure Policy--Policy must be available before or at the time the per- sonally identifiable information is requested or collected Provide Choice and Obtain Consent--Individuals must have a choice on how the personally identifiable information may be used or have the opportunity to opt out of such use Ensure Data Security--Appropriate measures must be taken to ensure that personally identi- fiable information is reliable and protected from loss, misuse, and alteration Ensure Data Quality and Access--Reasonable steps must be taken to ensure that data are accu- rate, complete, and timely 6.5 Current Trends The trend for managing smartcard-related data is to adopt the most conservative approach: Each agency owns the transaction data generated in its system. Any transaction record related to an adjoining agency's service, such as a transfer, is to be made available only to the respective agency involved in the transaction. Only ridership reports required by the FTA, through other inter-agency agreements, or through other public sources, may be available to all participants. Financial and revenue data are to be reported on an aggregated basis, and each agency controls the distribution of its financial and revenue data. As interoperable systems become more common and economic benefits begin to materialize as a result of wider sharing of data, transit agencies may begin to cede the tight control common in the industry today.