House Sign-on Letter: Spirit Airlines & Google Need Guardrails for Sensitive Employee Data Transfer

October 1, 2026

Dear Representative:

On behalf of our affiliated unions representing hundreds of thousands of airline workers, the Transportation Trades Department, AFL-CIO (TTD) urges you to sign onto a letter led by House Labor Caucus Co-Chair Congressman Steven Horsford (NV-04) expressing concerns regarding the proposed $10 million sale of Spirit Airlines’ internal data of current and former employees to Google to train its Artificial Intelligence (AI) products.

The letter urges Spirit and Google leadership to commit to guidelines for handling sensitive employee information if a data transfer occurs. This data includes training records, payroll data, disciplinary records, medical accommodations, and much more, all of which require heightened protections. Google will gain access to a large amount of sensitive employee data, which highlights the absence of privacy safeguards for workers.  Current protections for employee data are much weaker than those for consumer data– especially in a bankruptcy sale.

As the nation’s largest transportation labor federation, TTD represents hundreds of thousands of workers who build, operate, and maintain our transportation network across the United States. We thank Members for considering working people’s perspective on this matter and urge you to join Congressman Horsford in signing this letter.

To sign on, please use this Quill link or contact Jenna Poleykett in Congressman Horsford’s office at Jenna.Poleykett@mail.house.gov. The deadline to sign this letter is Wednesday, October 7, 2026, COB. For more information or if you have any questions, please contact TTD’s Senior Legislative Representative, Lianne Endo, at LianneE@ttd.org. 

Sincerely,

Greg Regan, President
Transportation Trades Department, AFL-CIO

The following letter is endorsed by:

Air Line Pilots Association, International (ALPA)
Association of Flight Attendants-CWA (AFA)
International Association of Machinists and Aerospace Workers (IAM)
Transport Workers Union of America (TWU)
Transportation Trades Department, AFL-CIO (TTD)

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LETTER TEXT

October 8, 2026

Mr. Pichai and Mr. Davis,

We write to express serious concern regarding the proposed $10 million sale of Spirit Airlines’ internal data to Google for the purpose of training artificial intelligence systems and the implications of that transaction for the privacy and confidentiality of thousands of current and former Spirit employees.

This sale presents uncharted territory. According to publicly available court findings, the proposed sale would involve an extraordinary volume of Spirit’s internal records, including approximately 100 million emails, 500 million Microsoft Teams messages, employee records, timecard records, payroll and tax information, and employment contracts. This information was created and provided in the context of an employment relationship and may contain highly sensitive information about individual workers. Consumers have more privacy protections than workers, yet Spirit has collected far more private information about its employees than about its customers.

While we understand that Google has stated that it will not receive personally identifiable information and that the data will undergo third-party scrubbing before its transfer, we are concerned that conventional de-identification safeguards may not be sufficient to protect employee privacy in the context of modern artificial intelligence. Removing names, email addresses, or other direct identifiers does not necessarily make a dataset anonymous. As we have seen time and time again, artificial intelligence systems have been able to identify patterns across large datasets, connect seemingly unrelated pieces of information, and potentially infer or reconstruct information about individuals or identifiable groups. In fact, the National Institute of Standards and Technology has recognized that de-identified data can – in some circumstances – be re-identified and has emphasized the importance of evaluating re-identification risks.

That is why, before any employee-related information is potentially approved and transferred, we urge Google and Spirit to take the following steps:

1. Exclude employee information from the transaction to the greatest extent possible. At a minimum, employee training records, timecards, payroll information, and Microsoft 365 content containing flight attendant information should be excluded from any data transferred to Google. Where information can be segregated without compromising legitimate business records, employee information should not be included in the transaction simply because it is technically capable of being transferred.

2. Establish a meaningful de-identification protocol agreed upon by the affected workers. Any de-identification protocol should be developed with meaningful input from affected employees and should account for specific risks associated with combining large volumes of employment, communications, and operational data.

3. Protect sensitive employee information even when it has been de-identified. Employee information should not be treated as non-sensitive simply because direct identifiers have been removed. Spirit and Google should ensure that disciplinary records, training deficiencies, medical or accommodation requests, compensation information, and other sensitive employment information receive heightened protections. Those protections should also account for the possibility that individuals or small groups of workers could be identified through combinations of communications, operational records, crew base information, employment history, or other datasets.

4. Establish an independent employee confidentiality review and meaningful limits on downstream use. An independent review should be conducted of all employee-related information proposed for transfer to determine whether it contains confidential or sensitive information, including information that could become identifiable when combined with other datasets. Any transfer should be subject to enforceable restrictions governing the subsequent use, disclosure, retention, or transfer of employee information by Google or any third party.

5. Establish a formal review protocol and prohibit profiling identifiable groups of workers. Where employee information cannot be excluded, Spirit and Google should establish a formal review protocol for labor records, disciplinary records, training information, and employee communications before any transfer occurs. The parties should also expressly prohibit the use of the data to identify, profile, evaluate, or draw inferences about identifiable groups of flight attendants or other workers.

6. Exclude Information Related to De-Identified Voluntary Safety Programs. Exclude all information relating to voluntary safety-related programs, including but not limited to fatigue management, the Aviation Safety Action Program (ASAP), Flight Operations Quality Assurance (FOQA), and Line Operations Safety Assessments (LOSA). Airline safety relies on voluntary reporting by pilots and other employees. Inadvertent disclosure of safety-related data either through improper de-identification or otherwise threatens future cooperation in these vital programs for the FAA, air carriers and other participants.

Innovation should not come at the expense of workers’ privacy or the confidentiality of information they were required to provide as a condition of employment. The unprecedented scale and sophistication of modern artificial intelligence make it particularly important that privacy protections keep pace with the technology.

We therefore urge Google and Spirit to address these concerns and establish meaningful, enforceable safeguards before the proposed transaction proceeds. At a minimum, no employee- related information should be transferred until appropriate protections are in place to ensure that workers’ sensitive information cannot be identified, profiled, or misused.

Sincerely,

[[SIGNATURES]]