Legal Issues in New IT @ Airports - SITA

Legal Issues in new
IT @ Airports
- the Integrator’s Perspective

Amsterdam WALA
27 April 2012

By: Stephen Baird, Legal Director, SITA
www.sita.aero

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

- What legal issues are raised?

- What‟s the integrator‟s perspective?

2
WALA - SITA Presentation: Legal Issues & IT@Airports | Confidential | © SITA 2012

AIRCRAFT
& AIRFRAME
MAKERS
Briefly - About SITA
AEROSPACE
SITA is owned by the air transport industry.
www.sita.aero
We work collaboratively with:
AIR
CARGO

AIRLINES
GOVERNMENTS

AIRPORTS
AIR
NAVIGATION GLOBAL INTERNATIONAL
SERVICE DISTRIBUTION ORGANIZATIONS
PROVIDERS SYSTEMS

A GLOBAL CUSTOMER BASE

Providing services
across 200+ countries
and territories

Stakeholders | Services | … Let‟s travel …

5

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 Barkley
Flight United UA 582
to Chicago
Leaving 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 space
2. once parked, tags parking location to easily find his car upon his return

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

Proceed to
Security Lane #3

This way

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

1. Mr. Barkley is
informed of Alpha Retail Offers
Alpha Retail

relevant and
personalised
special offers
based on his
location
ACCEPT DECLINE
Select Back
Back
2. He purchases
items using his
mobile phone for
checkout and
payment

Meanwhile, Mr. Barkley's
aircraft has landed.

Handling crews are
optimally allocated
Flights

and supported by
the Airport FA123 SK456 SO768

Refuelling:
Management System 78% complete
Apron Mgr.
via information
pushed on their
handheld devices

Gate handling staff too is proactively
informed of potential time-breaches via
mobile devices and resources
are allocated based on
real-time data (passenger Gate-handling status
Gate 44
status and location) BA1365
Planned Actual
Gate open 8.05 8.05
Cabin crew reported 8.10 8.15
Boarding started 8.15 8.17
Pax yet to board 15 30
Cabin door closed 8.40
Gate closed 8.42
January 28, 2009 08:31

Mr. Barkley
is informed
that
boarding Mr. Barkley, your
flight UA 582
has begun to Chicago
is now
(suggested BOARDING
itinerary Please proceed to
gate T15
with ETA) Estimated time to
reach gate: 6 min.
Suggested itinerary

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

Three areas of legal focus:

1. Airport Passenger 2. Wireless 3. Shared use IT
Tracking Networking Infrastructure
Poised for Legal
Efficiency &
rapid options and
massive
growth – models for
data
raising data new infra-
transfer
issues structure

15

1. Airport Passenger Tracking and
Legal Issues

16

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
17

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

18

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.)

19


• 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? Mr Barkley
Flight United
UA 582

• Revenue share with airlines?
to Chicago
09:38PM
Status:
ON TIME
Gate: T15

• iPhone / Android apps?
• Loyalty / FF cards?
Over 70% of bus. class pax have 1+ FF.
• Gather it using other incentives?

20

• 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.

21

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.

22

2. Wireless Networking and Legal
Issues

23

Wireless: What‟s the available technology?
Data transfer
o 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
Tracking
o 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 / Validation
o Near-field Communication (NFC)
• Smartphone (or chip) radio comms eg. Swiping for access – 5cm range
24

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

How will wireless networks be used?
Linking:
Airlines now
• Each pax  Airport issuing
tenders for
• Each aircraft  Airline‟s data centre (via many „000s
ground n/w)
of iPads
• Each pilot  Airline / Airport with wifi

• 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

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?

27

Security for Wireless Networking
• 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

28

Legal Issues in Wireless Networking @Airports
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.

29

3. Shared-use IT Infrastructure
and Legal Issues

30

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.

31

Legal Models for Shared-use Supply
Common Use – HYBRID – Airport Sourcing –
“CLUB”* model “Airport joins CLUB Option” “Direct” model

Airlines/GHAs buy “CLUB” model but airport joins Airport buys
services as a group/ the group as a non-fee paying services, resells to
committee. committee member. airlines/GHAs.

ADVANTAGES: ADVANTAGES: ADVANTAGES:
Airport has no Enhanced collaboration. Airport Airport is in full
operational liability. can influence committee and control as sole
Airport is free to sell has voting power – veto voting reseller of service to
additional services. power possible. airlines/GHAs

DISADVANTAGES: DISADVANTAGES: DISADVANTAGES:
Airport cannot Airport is not in full control as in Airport is liable to
control service. “Direct” model. airlines/GHAs as
service provider.

* CLUB stands for Less used than other models today – but
“Common-use Local useful if airport seeks to retain a level of
Users Board”. (Not a control / influence while avoiding full
legal entity.)
liability of “Direct” model

Legal Issues in Shared-use IT@Airports
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.

33

Legal Issues in New IT@Airports
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.

34

THANK YOU

Stephen Baird
Legal Director
stephen.baird@sita.aero
www.sita.aero
LinkedIn:
http://www.linkedin.com/pub/stephen-baird/19/9b0/966

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