Right from the start, GS1 recognized that there would be privacy concerns associated with the use of Electronic Product Code (EPC) technology. Putting a radio frequency identification transponder with a unique identifier on every consumer product created the potential for abuse. So in 2003—well before the first consumer product had an EPC tag on it—GS1 published its Guidelines on EPC for Consumer Products. The guidelines, fully and formally adopted by the GS1 EPC community in 2005, cover four main areas:
1. Consumer Notice: Consumers will be clearly notified of the presence of EPC tags on products or in packaging through the use of an EPC logo or identifier on the products.
2. Consumer Choice: Consumers will be informed of their options to discard, disable or remove EPC tags from the products they acquire.
3. Consumer Education: Consumers will have the opportunity to easily obtain accurate information about EPC and its applications, as well as about advances in the technology.
4. Record Use, Retention and Security: As with conventional bar-code technology, companies will use, maintain and protect records generated through EPC in compliance with all applicable laws. Companies will publish, on their Web sites or otherwise, information on their policies regarding the retention, use and protection of any consumer-specific data generated through their operations, either generally or with respect to EPC use.
The guidelines state that GS1 would act as “a forum for both companies and consumers to learn of and address any uses of EPC technology in a manner inconsistent with these guidelines.” With growing interest in using EPC RFID technology to track individual clothing items, GS1 is, as part of its role as a forum, addressing current questions about whether EPC tags inserted in printed fabric labels attached to apparel items are acceptable.
“The EPC RFID tag inserted into a printed fabric label meets the requirements of the guidelines if it meets the notice and choice provisions in the guidelines,” says Paul Voordeckers, EPCglobal‘s president. “We do not think that the use of printed fabric labels require a change in the EPC Privacy Guidelines.”
However, GS1 will add this important information to its Frequently Asked Questions (FAQ) on Guidelines on EPC for Consumer Products, which support the guidelines document. EPCglobal’s Board of Governors has approved the following addition:
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Can EPC RFID tags be part of a fabric label sewn into an apparel item? The EPC RFID tag inserted into a printed fabric label meets the requirements of the Guidelines if it meets the notice and choice provisions in the Guidelines. If the consumer can easily cut the EPC RFID tag off the printed fabric label, or cut out the entire fabric label, then the “consumer choice” provision is met. Care should be taken with fabric care and content labels to ensure that removing the EPC RFID tag does not also remove the fabric care or content information. Consumers are likely to want to keep this information attached to the item. |
There has not been a lot of talk regarding privacy as it relates to RFID, but it’s good to see that GS1 recognizes that evolving applications of the technology—notably item-level inventory management within apparel stores—raise some issues that need to be addressed, and that it is, in fact, addressing them. I hope retailers that are deploying or piloting RFID in stores at the item level have read and are following the guidelines. That will help to avoid any potential problems with customers’ privacy.
Mark Roberti is the founder and editor of RFID Journal. If you would like to comment on this article, click on the link below. To read more of Mark’s opinions, visit the RFID Journal Blog, the Editor’s Note archive or RFID Connect.