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Privacy Concerns Raised

Industry Seeks Clarity on Implementation of Safe Connections Act Requirements

Industry and consumer advocates sought additional guidance and clarity on the FCC's proposed requirements to implement the Safe Connections Act, in reply comments posted Monday in docket 22-238 (see 2304140057). Commenters also showed widespread support for sufficient time to comply with the commission's final rules and additional guidance on potential privacy concerns. The act requires availability of safe access to communications services for survivors of domestic violence.

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The record shows a consensus on "limiting the role that wireless providers' representatives should play in determining an individual's eligibility" for the Safe Connections Act's protections, said CTIA. It urged the FCC to "provide sufficient time and opportunity" for implementation to account for "different processes, capabilities, and system limitations" for providers and the unique experiences of individual survivors.

Implementing the act will be a "complex undertaking" for the commission and providers, said NCTA. It agreed with other industry groups that providers shouldn't be required to verify a survivor's documentation demonstrating eligibility. Providers are "ill-equipped to accurately assess the validity of these materials and attempts to verify the information would risk retraumatizing the survivor," NCTA said. USTelecom agreed, saying "clarity regarding the scope of providers’ obligations will facilitate timely and consistent compliance."

"Systems and processes to exclude numbers from consumer-facing logs will take time to develop, especially for legacy systems," USTelecom said. The group noted some providers may not be able to begin implementation "until the parameters of the database and its operation are well defined." The FCC must provide "significant clarity to promote industry-wide compliance and to avoid unintended consequences," said the Competitive Carriers Association. The group sought additional guidance on the definition of “two business days” for compliance with rules and carrier liability issues.

Commenters showed "wide support" for designating Lifeline as the program to provide emergency communications services for survivors experiencing financial hardship, said the National Lifeline Association. The group noted that Lifeline doesn't have a "successful history with self-certification of eligibility," saying the FCC could address this by subjecting self-certification to national verifier review and "an ironclad safe harbor for service providers." Lifeline is "the right program to support survivors of domestic and sexual violence with voice and broadband services," NaLA said, asking the FCC to raise the monthly reimbursement to $30 and remove the minimum service standards "with simple rule changes."

The FCC should address privacy concerns about "dual-use" apps, or apps designed to be used as a family tracker, and other carrier apps that track location, said a coalition of consumer advocates, which included Electronic Privacy Information Center, Electronic Frontier Foundation and Public Knowledge. The groups backed NaLA's proposal to establish a pilot program offering discounted devices through Lifeline for instances where survivors may not feel safe using their preexisting device.

Accessibility advocacy organizations Telecommunications for the Deaf and Hard of Hearing, Inc., National Association of the Deaf and Communication Service for the Deaf urged the FCC to ensure survivors with disabilities can communicate with a covered provider "effectively and without difficulty." The groups said line separation requests through direct video calling services would be "the most accessible and effective service available" to complete a request.