Text-to-988 Georouting Plan Seeing Some Grudging Agreement About FIPS
Proponents of georouting text messages sent to the 988 Suicide & Crisis Lifeline are seemingly starting to coalesce around the use of federal information processing standards (FIPS) codes. That's according to docket 18-336 reply comments due Friday. The 988 call georouting order, which FCC commissioners approved in October, included an NPRM about text georouting (see 2410170026).
Sign up for a free preview to unlock the rest of this article
Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today!
Going with a text georouting solution that uses coarse location data will ensure that contacts made with the 988 Lifeline will be associated only with broad geographic data that protects user privacy, Vibrant Emotional Health said. Whatever route a carrier opts for, it should integrate with the existing 988 Lifeline network, Vibrant said. Georouting of texts to 988 doesn't need to rely on the existing text-to-911 infrastructure, which was designed for geolocation and would require network modifications, it added. Vibrant also pointed out that people who reach out to the 988 Lifeline expect a greater level of confidentiality than those who contact 911. The text-to-988 option closest to what it envisions is the one proposed by CX360, which would use county-level FIPS codes derived from cell tower information.
Citing privacy concerns, the Electronic Privacy Information Center and mental health advocacy group Wildflower Alliance said the FCC should eschew georouting altogether and go with a system in which those seeking help voluntarily provide their ZIP codes. If the FCC does move forward on georouting, it should rely on FIPS as "the least terrible among automated options." EPIC and Wildflower said it's not clear what legal authorities protect the data of people contacting 988, and the lack of uniform restrictions on storage and use of the data means that even Vibrant doesn't necessarily know what different data centers are doing or how the information is being shared. Thus, it's "implausible at best" that there can be meaningful consent.
The Conservative Political Action Coalition Foundation's Center for Regulatory Freedom suggested an informed consent model where people reaching out to 988 via text receive an automated text message back, asking for permission to share georouting data with the 988 Lifeline administrator. That kind of framework would ensure that 988 users provide explicit consent, including about what information will be collected and shared and for what purpose, the center said. It said there also could be methods for a user to revoke their previously given consent.
CX360 urged the FCC to set a general obligation on wireless carriers for a text-to-988 georouting solution, with a clear preference for routes that rely on coarse location data such as county-level FIPS codes. It also urged an implementation time frame of at least 12 to 18 months.