ORCA-Watch

Public Transportation and Your Privacy

What is ORCA?

The Regional Fare Coordination System, popularly known as ORCA, is a public transportation program for King, Pierce, Snohomish and Kitsap counties. Coming in 2009, it will replace all magnetic strip, paper-based tickets and transfers with a radio frequency identification (RFID)-embedded smartcard. If you get a discounted pass from your school or employer, or you prepay for your own pass by the month or year, you'll get an ORCA card.

The RFID transmits a unique number that enables the transit system to recognize the card each time it is used. A transit system database will capture the exact date and time of use, as well as what route and transit agency was used. Transit agencies will be able to access a history of individual transactions, showing when a card was used to board specific buses, trains, ferries and vanpools. This information will go to organizations providing discounted fare passes.

Privacy Concerns

The ACLU is watching ORCA to make sure safeguards and policies are put in place to prevent others from tracking every time you ride public transit.

UPDATE: Following the presentation of our concerns to the joint board of Transit Directors, the ACLU received a letter stating that, "the Board subsequently directed our contractor to make system design updates to the web site that are consistent with your recommendations."

Concern:

As currently proposed, organizations that provide discount passes will have access to an individual's public transportation history, even travel done on your own time. Transaction details about date, time and route number can reveal personal information about your life, and access to this information would enable others to track your activities. An employer should not be able to know where you go to worship each weekend. Nor should schools know who took a bus after a nearby protest ended.

Solutions:

Create a policy to protect the privacy of an individual's transaction history.

Provide organizations subsidizing fare passes only aggregate or less detailed information that does not reveal date, time and route number.

Concern:

Unauthorized reading or "skimming" of information on the ORCA card's RFID chip may put people's privacy and safety at risk without their knowledge. To enable fare payments, ORCA cards will store and transmit information about recent rides, along with a unique card identification number. An unchanging unique identification number - when attached to a person or that person's card - can become a means for others to monitor that person's movements. ORCA cards should not transmit information to potential stalkers or anyone else looking to collect information about your travels.

Solutions:

Ensure that only legitimate transit agency readers can access unique identification numbers or other information stored on ORCA cards.

Ensure that unauthorized parties cannot track a card by through the RFID tag's unique identification number.

Concern:

Information about an individual's transportation usage will accumulate and be reused for unintended purposes. Other organizations and individuals may seek to obtain database information about how and when individuals ride public transit. In other states, third parties already are obtaining details of individuals' travel histories for use in divorce and custody cases - all they need is the card number associated with the fare pass and transaction history.

Solutions:

Create a policy to retain an individual's transaction data only for the shortest time required by law.

Maintain only aggregate transaction information for transit analysis and planning purposes.

Public Documents about ORCA

Through a request under Washington's Public Disclosure Act, we have obtained some key documents describing the program.

RFCS High Level System Overview (Adobe PDF)
• Training course material that provides an overview of the ORCA system.
ORCA Contract Equipment Specifications (Adobe PDF)
• Section of the ORCA project contract that outlines equipment specifications.
ORCA Contract Service Specifications (Adobe PDF)
• Section of the ORCA project contract that outlines service specifications.
Sample ORCA Report: Institutional Card Account Transaction History (Adobe PDF)
• An excerpt from a report generated for the ORCA beta test. This report displays information for cards provided through employers, schools and agencies (i.e., institutions), and shows the time and route of each boarding over time for an individual card/person.
ORCA Institutional Program Website Functional Specification (Adobe PDF)
• Details about the website for ORCA institutional partners (e.g., employers, educational institutions, public agencies) and transit agency representatives.

More Resources

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