Equity in Civic Technology, Privacy & Data
CDT Urges FCC to Protect Student Privacy and Bolster Equitable Online Access in Establishing Affordable Connectivity Fund
Executive Summary
The Center for Democracy & Technology (CDT) respectfully submits these comments in response to the Public Notice issued by the Wireline Competition Bureau, seeking public comment on the new Affordable Connectivity Program established by the Infrastructure Investment and Jobs Act.
CDT applauds the efforts of Congress and the Commission to close the homework gap and bridge the digital divide and offers these comments on how to connect students and families while protecting their privacy. The Affordable Connectivity Program provides critical resources to connect students learning from home to their lessons and to help make broadband affordable for low-income families. However, a failure to garner students’ and families’ trust can chill participation and hamper the Program’s effectiveness. To help earn that trust, the Commission should protect students’ and families’ privacy by:
- Clarifying that the monitoring requirement of the Children’s Internet Protection Act does not require schools to engage in pervasive tracking of students’ online activity.
- Using school enrollment data—rather than sensitive individual eligibility data—when possible to verify students’ participation in the National School Lunch Program or the School Breakfast Program, including by maintaining eligibility for students who attend a school participating in the Community Eligibility Provision.
- Reconsidering the Bureau’s interpretation of the timeline for rulemaking under the Infrastructure Investment and Jobs Act in order to ensure that schools and communities may fully and equitably participate in the establishment of the Affordable Connectivity Program.
