CDT submitted a reply comment to the Federal Communications Commission (FCC) in March in response to a Notice of Proposed Rulemaking issued by the Commission, seeking public comment on the creation of labels to disclose information about broadband services offered by internet service providers (ISPs) to consumers. CDT urged the FCC to require ISPs to include specific information about their privacy practices in their consumer labels. CDT has long advocated for robust limits on data collection, sharing, and use to lessen the burden on consumers and better protect their privacy. As we continue to wait for comprehensive federal privacy legislation, more can be done to address privacy-invasive data practices. Disclosures on consumer broadband labels present one such opportunity.
Specifically, CDT’s comment:
- Details how ISPs’ privacy practices necessitate the addition of easily-understood privacy disclosures to the consumer labels;
- Identifies specific privacy disclosures that should be included in all labels in order to best address the most harmful practices; and,
- Explains how requiring privacy disclosures is well within the Commission’s authority under the Communications Act and the Constitution.