Monday, March 11, 2013

Is it time to annoint a 'Papa Smurf' of NYC entrepreneurs?

Manhattan has long been a place where lurid busineses have operated under the cover of legitimate fronts.

During the prohibition era of the 1920's, it is estimated that between 20,000 and 100,000 speakeasies existed in New York City. When alcohol was banned, bars did not disappear, but simply went underground (to basements and attics), and were disguised behind front businesses, such as cafes, soda shops, and entertainment venues.

Today, organized crime leaders use legitimate businesses, such as laundromats or limousine companies, as fronts for illegal activity, such as trafficking and racketeering. In October of last year, eight members of Brooklyn-based motorcycle gangs (the Forbidden Ones, the Dirty Ones, and the Trouble Makers) were charged with trafficking for selling firearms, ammunition and a cannon. The trafficking businesses were run under the front of legitimate tattoo parlors operated by the gangs. In January of this year, 32 members of New York's Genovese, Gambino and Luchese Mafia families were arrested for engaging in racketeering, extortion, loansharking and fraud under the front of a legitimate private garbage hauling business.

Due to such high profile arrests, the use of legitimate businesses by organized crime syndicates as fronts for illegal activity is well known. It is my contention that there is an analogous practice, namely the use of legitimate businesses as fronts for activity that is certainly unethical (and arguably illegal), that is even more prevalent in New York City, but less well known. And it is not the organized crime syndicates that are running this racket, it is the entrepreneurs in the New York start-up scene. I am refering to the advent of start-up companies as fronts for the collection of big data.

This is particularly true in the real estate sector. Many start-up companies are setting up shop under the mandate of revolutionizing New York's notoriously tough rental property market. However, these businesses are in reality a front for the main objective of collecting big data about the prospective tenants. More so than Facebook or Twitter, or the various other forums companies use for collecting information, in the real estate setting, companies are uniquely placed to collect highly sensitive information about people. Where else would you voluntarily reveal information so intimate as residential history, pay slips, tax returns, and social security numbers? This information is highly valuable to the companies collecting it, and its collection is, in fact, the companies' primary business objective.

As I said above, indeed, unlike traficking or racketeering, the collection of big data is not per se illegal. Thus, these start-up companies cannot be deemed the same as the organized crime syndicates, but are nevetheless analogous to them. There is something that feels “icky” about these companies knowingly and purposefully operating cover services as fronts for the real business of personal data collection. Certainly issues of ethics and privacy arise.

I am Australian, and as a citizen of a country that does not even have a national Bill of Rights, sometimes the number and nature of the Bill of Rights that exist in the US seems laughable. (For example, there is a New York City Taxi Cab Bill of Rights, guaranteeing such supposed fundamental and crucial rights as “airconditioning on demand” and “a clean trunk”.) But, in regards to the use of businesses as fronts for the collection of big data, a Bill of Rights seems in order. Obama's Consumer Privacy Bill of Rights, unveiled in February of last year, is an imperitave tool in the effort to regulate this practice.

The Consumer Privacy Bill of Rights establishes regulations including that companies should securely dispose of (or de-identify) personal data once they no longer need it, unless they are under a legal obligation to do otherwise. That is, companies could well be required to dispose of income statements as soon as they have been perused to ascertain that a prospective tenant meets the threshold requirement for leasing a property, thus preventing the companies from using the income information for any other, unauthorized purposes and eliminating the incentive for the companies to deceptively operate businesses as fronts for collection of data on which they can then capitalize.

When it comes to using start-up companies as fronts for the collection of big data, the lines of illegal activity and legitimate business strategies are blurred and somewhere in the ill-defined murk, lies activity that seems dubious to say the least. The ethics is debatable. The privacy issues are rife. Public awareness, scrutiny, and regulation is required. The implementation of the Consumer Privacy Bill of Rights cannot happen soon enough. 

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