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Equity in Civic Technology, Privacy & Data

CDT’s Comments to FCC on Emergency Broadband Benefit Program

Getting students online is fundamental to ensuring that their learning may continue during the ongoing COVID-19 crisis. Identifying students that are in need of support, however, can require sensitive student information such as income or participation in government benefits.

CDT provided these comments on the FCC’s proposed Emergency Broadband Benefit to help ensure that students and families can get connected without sacrificing their privacy and to ensure they have the resources they need to get online securely and safely.


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 a new Emergency Broadband Benefit Program, as established by the Consolidated Appropriations Act, 2021.

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 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:

  • 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, especially when the school has adopted the Community Eligibility Provision.
  • Fully enabling students’ participation in the Program by providing cybersecurity and digital literacy training and clarifying disparate applications of the monitoring requirement of the Children’s Internet Protection Act.

In addition to these education-specific recommendations, CDT also suggests that the Commission adopt privacy-forward and equitable data practices to ensure the Program achieves its goal of closing the digital divide while protecting individual rights by:

  • Limiting broadband providers’ data collection and use under the Program.
  • Avoiding inadvertent disclosures of personal information while meeting data reporting and accountability requirements.
  • Prioritizing marginalized communities and students under the Program through the review of applications, outreach, and technical support.

Read the full comments here.