legal issues in new it @ airports - the integrator’s perspective amsterdam wala 27 april 2012 by:...

Legal Issues in newIT @ Airports - the Integrator’s Perspective

Amsterdam WALA

27 April 2012

By: Stephen Baird, Legal Director, SITA

2

- What’s new in the world of IT @ Airports?

- What legal issues are raised?

- What’s the integrator’s perspective?

WALA - SITA Presentation: Legal Issues & IT@Airports | Confidential | © SITA 2012

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5 WALA - SITA Presentation: Legal Issues & IT@Airports | Confidential | © SITA 2012

1. From his home, Mr. Barkley:− Checks in online− Downloads airport portal to phone to

register his preferences (food, books, …)− Prints boarding card and bag tag

2. Portal pushes flight status

Mr BarkleyFlight United UA 582 to ChicagoLeaving at 09:38PM

Status: ON TIME

Gate: T15

Mr. Barkley drives to airport (directions on mobile phone GPS system):1. asks where to park and books/prepays his parking space2. once parked, tags parking location to easily find his car upon his return

Proceed to Security Lane #3

This way

1. Mr. Barkley drops off his bag (and will know at all times where it is thanks to end-to-end bag tracking)

2. The portal directs him to shortest security queue via augmented reality interface

Mr. Barkley goes through biometrics- enabled security & documentation control(faster and more secure procedures)

1. Mr. Barkley is informed of relevant and personalised special offers based on his location

2. He purchases items using his mobile phone for checkout and payment

ACCEPT DECLINEBack

Alpha Retail Offers

Select Back

Alpha Retail

Select Back

Meanwhile, Mr. Barkley's aircraft has landed.

Apron Mgr.

Flights

SK456FA123 SO768

Handling crews are optimally allocated and supported by the Airport Management System via information pushed on their handheld devices

Refuelling:78% complete

Gate handling staff too is proactively informed of potential time-breaches via mobile devices and resources are allocated based on real-time data (passenger status and location)

January 28, 2009

08:31

Gate-handling status

Gate open

Cabin crew reported

Boarding started

Pax yet to board

Cabin door closed

Gate closed

8.05

8.10

8.15

15

8.40

8.42

Planned

BA1365

8.05

8.15

8.17

Actual

Gate 44

30

Mr. Barkley is informed that boarding has begun (suggested itinerary with ETA)

Mr. Barkley, your flight UA 582 to Chicagois now BOARDINGPlease proceed to gate T15

Estimated time to reach gate: 6 min.

Suggested itinerary

He reaches his gate where he is able to self-board without queueing

15

Three areas of legal focus:

Poised for rapid

growth – raising data

issues

Efficiency & massive

data transfer

Legal options and models for new infra-structure


1. Airport Passenger Tracking

2. Wireless Networking

3. Shared use IT Infrastructure

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1. Airport Passenger Tracking and Legal Issues


17

Pax Tracking – What is it?

• “Passive” anonymous tracking vs.• “Active” tracking and “push” interacting:

• Automatically validating access to secure areas• Sending boarding information• Marketing

• If the passenger data is known:• You are gathering & storing pax personal data• You can “push” information to specific pax (with consent)

• Analyzing output data to improve:• Airport services for pax; and• Airport efficiency – in real-time


18

Consolidating and Analyzing Anonymous Data – P@A Dashboard – allowing real-time airport efficiency decisions

19

Using Personal Data @Airports

• Pushing information to known pax – using preferences and a phone no – must comply with data protection laws (if applicable in your country).

• Airlines cannot give data for direct marketing by third parties unless the pax has explicitly consented. (They can give it for airport operational or security reasons.)


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• How do you legally gather knowledge about people – mobile no., age, salary, what they like to read – and obtain their consent to enable direct marketing?

• Buy it from brokers?• Revenue share with airlines?• iPhone / Android apps?• Loyalty / FF cards?

Over 70% of bus. class pax have 1+ FF. • Gather it using other incentives?


Mr BarkleyFlight United UA 582 to Chicago09:38PMStatus: ON TIMEGate: T15

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• Once you have data, under data protection laws:• It can only be used in line with the original consent;• The pax retains ownership and rights eg. to have it

“forgotten” (in EU);• It must be stored securely.

• Passing the data to subcontractors is often possible, but you must “control” the data at all times.

• In the context of cloud services, data “control” means: Access control; Ability to inspect access logs; Ability to alter storage instructions.



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Legal Issues in Passenger Tracking@Airports

SUMMARY

• Airports have the opportunity to be at the forefront of consensual direct marketing via social media – driving both pax satisfaction and beneficial marketing.

• Meaning that airports will become experts in personal data laws and data storage security issues.

• Control and security of data is key.


23

2. Wireless Networking and Legal Issues


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Wireless: What’s the available technology?Data transfero Wifi

• Range <100 metres; speed usually 54 MBps

o 3G cellular• Existing networks are PCI secure

o WiMax (4G)• Range 50km; faster than wifi• Some spectrum is regulated, some is not

Trackingo Bluetooth

• Accurate to +/- 5 sec. / 8-15% pax penetration / range = 10m

o Wifi • 25-50% pax penetration and growing

o Laser/Video/Thermal• Accurate to +/- 2-3%

Pax Access / Validationo Near-field Communication (NFC)

• Smartphone (or chip) radio comms eg. Swiping for access – 5cm range

How will wireless networks be used?Linking:

• Each pax Airport• Each aircraft Airline’s data centre (via ground n/w)

• Each pilot Airline / Airport• Airport agents Airport operations• Airside staff Airport operations

3,000+ aircraft with new, heavy wireless networking requirements in next 2-3 years: B777, B787, B747-8, A380, A350 plus retrofits

How to securely download 3 GB of mission critical

data in 45 min?

Airlines now issuing

tenders for many ‘000s

of iPads with wifi

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Wireless networks: Internal Efficiencies | New Services

• Airports are drawing up plans for: (Source: SITA research)

1. Mobile workforces; and

2. Aircraft-dedicated wireless services

Mission critical; both require professional grade wifi

• Challenges: • How to anticipate future technology• Airlines desire a single integrated global system • SECURITY: Who will be liable for hacking incidents?


3,000+ aircraft with new, heavy wireless networking requirements in next 2-3 years: B777, B787, B747-8, A380, A350 plus retrofits

How to securely download 3 GB of mission critical

data in 45 min?

? Great coffee!

Security for Wireless Networking

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• Payment Card Industry Data Security Standard (PCI DSS) should be aimed for – provides a high standard.

• To seek to protect and mitigate risks of hacking, technical design steps are needed. Nine examples:

SSID (WLAN) hidden from view; 802.1x security requiring user authentication; Certificate based security; Encryption; Firewalls; Traffic management - inbound traffic denial;Testing for rogue access points; Audit log management;Deploying wireless Intrusion Prevention/Detection.

• Infrastructure investment in airport wifi networks

will often be necessary to achieve PCI compliance.

Device W-LAN Ground LAN Ground WAN. No weak links


Legal Issues in Wireless Networking @Airports

29

SUMMARY

• Wireless networks offer airports significant possible revenue growth. Security is a value-add.

• Reasonable liability disclaimers will be sought.

• A robust, standardised and secure service will support heavier use – by the thousands of next-gen aircraft and devices (iPads etc) soon to come online at airports.


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3. Shared-use IT Infrastructure and Legal Issues


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What is Shared-use / Common-use?

• Infrastructure/equipment that is used by multiple airlines/GHAs, and contracted by those airlines/GHAs.

• First occurred in 1980s. The following can be supplied on

a common-use basis:

Existing:• Check-in desks / peripherals• Check-in kiosks

New:• Automated “intelligent”* security gates• Self-boarding gates• Self-service bag drop machines


* E-Gates have the intelligence, through sensors, to detect if there are any abnormal passenger behaviors such as piggy-backing/tail-gating or reversing direction.

Legal Models for Shared-use Supply

HYBRID – “Airport joins CLUB Option”

Common Use – “CLUB”* model

Airport Sourcing – “Direct” model

Airport buys services, resells to airlines/GHAs.

ADVANTAGES:Airport is in full control as sole reseller of service to airlines/GHAs

DISADVANTAGES:Airport is liable to airlines/GHAs as service provider.

Less used than other models today – but useful if airport seeks to retain a level of

control / influence while avoiding full liability of “Direct” model

“CLUB” model but airport joins the group as a non-fee paying committee member.

ADVANTAGES:Enhanced collaboration. Airport can influence committee and has voting power – veto voting power possible.

DISADVANTAGES:Airport is not in full control as in “Direct” model.

Airlines/GHAs buy services as a group/ committee.

ADVANTAGES:Airport has no operational liability. Airport is free to sell additional services.

DISADVANTAGES:Airport cannot control service.

* CLUB stands for “Common-use Local Users Board”. (Not a legal entity.)

Legal Issues in Shared-use IT@Airports

33

SUMMARY

• Shared-use IT infrastructure in airports has been around for decades – and is likely to remain for many years to come, because it’s convenient and efficient.

• As new “intelligent” IT infrastructure is launched, airports can choose the most beneficial model for shared-use IT for the airport and stakeholders.


Legal Issues in New IT@Airports

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FINALLY: SUMMARY of the SUMMARIES

• Passenger Tracking: Gather & use personal data lawfully & “control” it using access control, etc.

• Wireless Networks: Accept liability measured against value-add & actual security of the network.

• Shared-use: Consider hybrid shared-use model to ensure future collaborative decision-making.


THANK YOU

Stephen BairdLegal [email protected]

LinkedIn:http://www.linkedin.com/pub/stephen-baird/19/9b0/966

http://www.sita.aero/

http://www.linkedin.com/pub/stephen-baird/19/9b0/966

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legal issues in new it @ airports - the integrator’s perspective amsterdam wala 27 april 2012 by:...

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