The federal government is working on revamping America's 911 service, with a project called Next Generation 911. The goal is to create a framework that will allow consumers to contact critically important emergency services through multiple means — including text message, photos, and email — in order to improve responsiveness and accessibility. This is a wonderful opportunity that could help keep Americans safer. But as this system develops, it's important to engineer in privacy safeguards. In comments filed with the Federal Communication Commission today, EFF outlines the critical privacy concerns at play in Next Generation 911: medical privacy, locational privacy, and anonymity.

For example, one proposal for Next Generation 911 includes providing data like medical histories to first responders. It's an intriguing idea that could give emergency service teams a jump on providing urgent care to people in need. But in most places across the country, calls to 911 are subject to public disclosure. This has allowed communities to assess the responsiveness of emergency systems when considering funding and other questions. If medical histories and other sensitive data become part of Next Generation 911, the FCC should create provisions that specifically protect them from public disclosure.

Another tricky area is locational privacy. Many consumers have opted in to services that provide location-specific emergency calls, like a car's OnStar system that will alert a dispatcher if the airbag is deployed or home burglar and fire alarms that automatically contact emergency services when triggered. But others consumers don't want or need their cars or homes sending emergency signals without their consent, and it might lead to waste and misuse as well. Every time you burn a cake in the oven you don't need the fire department, for example. The FCC should respect consumer choice in this area.

The FCC is also exploring possible location sharing and authentication for "callers" who use the Internet to contact emergency services, which could have wide-ranging ramifications for anonymous speech. Online anonymity is an important tool for many users whose work or safety may be at risk — survivors of domestic violence and stalking, whistle-blowers, human rights workers, and individuals who suffer from sensitive medical conditions like HIV are just some examples. Any attempt to authenticate identities of online users, even under the guise of improving emergency services, could jeopardize that anonymity. We strongly object to any attempt to systematically anchor online identities to the offline world and any attempt to mandate online location sharing without consumers' consent.

Privacy isn't the only important issue at stake in Next Generation 911 — there are important innovation questions as well. Worldwide, there has been an explosion in consumer electronics that promote information sharing and communication. A technology mandate to engineer emergency services into all such devices — like laptops, netbooks, and other gadgets — could increase costs and chill innovation, preventing smaller companies from entering the market with creative new devices. Instead, the FCC should allow tech companies to promote Next Generation 911 compliance as a competitive feature and benefit.

The lightning-quick evolution of communications technology has proven a boon for public safety, making it cheaper and faster to call for help in case of an emergency. Electronic communications have made far easier to get help today than only a few years ago. This trend will continue. But not all communications devices need to be regulated in the same way. The core priority should be ensuring that the means of communication are numerous, ubiquitous, and readily comprehensible. New devices do not need any one particular feature to be a benefit to public safety. We hope the FCC will respect consumer privacy, choice, and innovation in Next Generation 911.