Apple has responded to the Canadian Radio-television and Telecommunications Commission (CRTC) regarding the privacy and data use of its Emergency Location Service (ELS) and Hybridized Emergency Location (HELO) technology.
The response comes after a request from Mr. Michael Murray, Director of Dispute Resolution and Regulatory Implementation at the CRTC.
In its letter dated June 14, 2024, Apple emphasized that privacy is a fundamental human right in its typical fashion, stating, “We design our products and services to minimize how much personal information Apple – or anyone else – can access.”
The company highlighted its efforts to limit data access through data minimization, user-controlled permissions, and encryption, particularly in emergency contexts where Apple devices only respond to location requests during emergency calls or texts. It also answered seven questions asked by the CRTC.
Apple clarified that HELO is a location estimation technology, not a transport technology. In Canada, HELO estimates are provided to Wireless Service Providers (WSPs) using standard protocols such as Session Initiation Protocol (SIP) and Presence Information Data Format – Location Object (PIDF-LO).
“Apple devices do not send HELO location estimates directly from the handset to a designated endpoint, such as a Public Safety Answering Point (PSAP),” the letter noted. Instead, HELO estimates are transmitted to WSPs using pre-existing, standardized location transports.
The company also addressed its role in Canada, stating, “Apple is not an ‘AML provider’ in Canada.” Advanced Mobile Location (AML) sends emergency location data via SMS or HTTPS to a central system. In Canada, this is unnecessary because Wireless Service Providers (WSPs) already support SIP and PIDF-LO protocols for emergency calls.
In comparison, Android devices use Google’s Emergency Location Service (ELS), which sends your location data directly to emergency services. The difference is Apple’s use of HELO sends your emergency location data to your mobile carrier first, which then forwards it to emergency services. Which one is better? I guess it depends on where you are and the infrastructure in place.
Regarding the data handling process, Apple explained that when a 911 call is placed, the device estimates the user’s location using available signals and sends this information directly to telecom networks. This ensures privacy by avoiding server-side calculations. “This location estimation process is device-based and requires no server-side calculation,” Apple stated, emphasizing that location information is sent only to the network handling the emergency call.
Apple confirmed that no personal information, as defined by the Privacy Act, is captured during a 911 call. “HELO location information is estimated on-device and transmitted directly to the WSP network carrying the emergency call,” the letter explained. This ensures that privacy is maintained throughout the emergency response process.
The letter was signed off by Tim Powderly, Apple’s Senior Director of Public Policy and Government Affairs for the Americas.
Thanks @fanCRTCProfling
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One would think that handling emergency calls and sending location information for same would be a standardized process, and not depend upon the type of phone used. As long as they both work, I guess.