FCC Data Breach Rules Pose Continuing Issues for Carriers: Akin
Carriers must continue following the FCC’s 2024 data breach rules after a recent U.S. Court of Appeals for the D.C. Circuit decision upholding a fine against T-Mobile, lawyers at Akin said Monday (see 2508150044).
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Providers should make certain “internal incident reporting protocols alert to all instances of access, use or disclosure of customer information, even unintentional or inadvertent mistakes,” the lawyers wrote. “This includes mishandled customer lists such as missent email attachments and not just threat-actor intrusion incidents.” Carriers should be prepared to engage counsel “to determine if any of these disclosures constitutes a ‘breach’ under the new rules, and revise reporting process documents to include the possibility of providing notification to the appropriate authorities within seven days of discovery.”