The Center for Democracy and Technology (CDT), along with EPIC, Privacy Rights Clearinghouse, and Public Knowledge, jointly filed reply comments with the Federal Communications Commission (FCC) urging the agency to prioritize protecting consumers from data breaches by explicitly naming and outlining its multiple sources of legal authority to protect privacy. As the comments explain, this authority includes the FCC’s power to protect Social Security Numbers and not merely phone service usage information (what is traditionally described as Customer Proprietary Network Information, or CPNI).
The advocates particularly urged the FCC to protect the privacy of Telecommunications Relay Service users (as TRS breaches could include transcript information) and non-customers (e.g., former customers and prospective customers). The comments reiterate that consumers should be informed of any breach and not be left in the dark just because the breached company has determined the breach is unlikely to result in harm. The comments also suggest that the Commission explore how the FCC and partner agencies might protect data collected from web-enabled vehicles.