Update as of January 2, 2025: The U.S. Court of Appeals for the 6th Circuit issued a decision on the consolidated petitions for review of the FCC's 2024 Open Internet Order. In its January 2 decision, which relies heavily on...more
Carriers have an obligation to protect customer proprietary network information (CPNI) and personally identifiable information (PI). Several recent FCC consent decrees resolving breaches of CPNI and PI show the FCC will hold...more
Last week, the FCC’s Enforcement Bureau (“Enforcement Bureau”) entered into a consent decree (“Consent Decree”) with prepaid calling provider TracFone Wireless (“TracFone”), addressing TracFone’s failure to adequately...more
As the FCC continues to exercise close oversight of the use of Customer Proprietary Network Information (“CPNI”), telecom stakeholders should also be sensitive to potential data security obligations under any relevant...more
The FCC continues to take a more active role in privacy with its enforcement of the customer propriety network information (“CPNI”) regulations. Recently, the FCC released Forfeiture Orders against the three largest mobile...more
Key Takeaways: The Federal Communications Commission (“FCC”) sent a loud message to the telecommunications industry: the era of lax CPNI compliance is over. - Mobile network operators (MNOs), mobile virtual network...more
Early this week, the Federal Communications Commission (FCC) announced it had fined the largest U.S. wireless carriers for sharing access to customers’ geolocation information without consent and without taking reasonable...more
On March 5, 2024, the Department of Justice (DOJ) issued an Advance Notice of Proposed Rulemaking (ANPRM) regarding Access to Americans’ Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern. The...more
Dear Clients and Friends, As a reminder, telecommunications carriers and interconnected Voice over Internet Protocol (VoIP) providers are obligated to file their annual certification documenting compliance with the Customer...more
FCC Requests Comment on CPNI/SIM Change Authentication Item: In this Further Notice of Proposed Rulemaking (FNPRM), the Federal Communications Commission (FCC or Commission) seeks comment on whether to harmonize the existing...more
In the privacy world, confidential information relating to the nature, amount, or use of telecommunications services has always been subject to separate rules from other types of customer data. Prior to the advent of...more
The updated data breach notification rules broaden the definition of what is considered a breach and expand the scope of who must be notified when a data breach occurs. The Federal Communications Commission (FCC or...more
The FCC has significantly expanded telecommunications carriers’ data breach notification and reporting obligations. Telecommunications carriers, including Voice over Internet Protocol (VoIP) services, and telecommunications...more
At the end of 2023, the Federal Communications Commission (“FCC” or “the Commission”) adopted updates to its existing 16-year-old data breach notification rules (“prior rules”) designed to ensure that sensitive customer...more
Key Point: The FCC revised its breach notification rules for telecommunication providers to broaden the instances when notifications are required, but even with limited exceptions to the new requirements, the final rule...more
FCC Seeks Comment on Expediting Initial Processing of Satellite and Earth Station Applications: In this Further Notice of Proposed Rulemaking (FNPRM), the Federal Communications Commission (FCC or Commission) reviews its...more
At its December meeting, the Federal Communications Commission approved a Report and Order modifying its data protection rules. The order expands the scope of protected data to include personally identifiable information....more
There has been a lot of coverage about the Federal Communications Commission’s (FCC and Commission) new and expansive data breach notification Order, approved on a 3-2 vote at the Commission’s December 13 Open Meeting. Much...more
The Federal Communications Commission (“FCC”) announced Thursday that in furtherance of the work of the agency’s Privacy and Data Protection Task Force, the FCC’s Enforcement Bureau signed Memoranda of Understanding (“MOU”)...more
Federal Communications Commission (FCC or Commission) Chairwoman Jessica Rosenworcel issued a Press Release yesterday announcing that the agency’s Privacy and Data Protection Task Force (Task Force) signed Memoranda of...more
On November 16, 2023, the Federal Communications Commission ("FCC" or "Commission") released a Report and Order and Further Notice of Proposed Rulemaking ("Order and FNPRM") revising the FCC's Customer Proprietary Network...more
In less than three months, public companies and certain foreign private companies will have to take additional steps after cybersecurity breaches: deciding whether an incident meets the materiality threshold that requires...more
On day two of Mobile World Congress (MWC), CTIA hosted a panel on “Promoting Security in a 5G World.” The panel discussed ongoing efforts by regulators and the ways that the wireless industry is responding to a changing...more
Recently, the FCC reminded telecom providers that the cost of failing to protect their customers’ privacy is steep. In a July 28, 2023 Notice of Apparent Liability for Forfeiture, the Federal Communications Commission fined Q...more
On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) adopted final rules regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies. The final rules require...more