TechFreedom joined a diverse array of public interest groups including the Competitive Enterprise Institute and the Center for Media and Democracy in a coalition letter expressing concerns about the consumer privacy risks posed by the Federal Communications Commission’s (FCC’s) Consumer Broadband Test and Mobile Broadband Test. These tests, according to the FCC, aim to provide citizens “better information about the quality and availability of their broadband and mobile broadband connections.” But the FCC appears to be collecting more personal information than necessary, failing to fully disclose what it is collecting, and providing this information to law enforcement without any due process or judicial scrutiny.
In the letter we urge the Commission to carefully evaluate the privacy implications of its broadband testing program and implement measures to enhance privacy, including:
- Disclosing personal information to other government agencies for purposes unrelated to broadband testing only when doing so is required by law;
- Minimizing its collection and retention of potentially sensitive personal information (e.g., street addresses and handset identification numbers);
- Where the collection of such information is justified, properly de-identifying the data to preserve its value while protecting the identities of individuals and their locations;
- Regularly disclosing how personal information, including street addresses, is retained, used, and shared with other governmental agencies; and
- Imposing the same limits on the public disclosure of IP addresses by the FCC’s contractors, M-Lab and Ookla, and its other software partners.