FCC Privacy and Data Protection Task Force State MOU

p52ppppThe Federal Communications Commission FCC announced Thursday that in furtherance of the work of the agencys Privacy and Data Protection Task Force the FCCs Enforcement Bureau signed Memoranda of Understanding MOU with the Attorneys General of Connecticut Illinois New York and Pennsylvania to share expertise and resources and to coordinate efforts conducting privacy data protection and cybersecurityrelated investigations  These states have been some of the most aggressive privacy and data security regulators in the past making these MOUs especially noteworthy ppIn addition the announcement indicates that the FCC intends to rely on authority under Sections 201 and 222 of the Communications Act to increase its investigation and enforcement activity concerning privacy data protection and cybersecurity issues  Section 222 generally requires carriers and VoIP providers to protect their customer proprietary network information CPNI such as servicerelated billing information  Under the current rules implementing Section 222 carriers and VoIP providers must notify customers the Federal Bureau of Investigation and the US Secret Service of data breaches that may have exposed CPNI  The FCC also has the authority to investigate breaches involving intentional unauthorized access to use or disclosure of CPNI ppLike the current announcement the FCC has taken other actions this year indicating that it believes its authority under Title II of the Communications Act the Act including Section 222 permits the agency to expand its current privacy data protection and cybersecurity activities ppFirst as we reported in January the FCC has proposed rules that would expand the scope of its breachreporting requirements to include inadvertent breaches as well as breaches involving information that can be used to distinguish or trace an individuals identity either alone or when combined with other information that is linked or linkable to a specific individual  In that proceeding the FCC proposes to rely on its authority under Section 222ppLikewise the FCC has recently proposed reclassifying broadband internet access service BIAS as a telecommunications service under Title II of the Communications Act  One stated reason behind the proposed change has been that by reclassifying BIAS as a telecommunications service the FCC can among other things expand its privacy data protection and cybersecurity authority with Chairwoman Rosenworcel explaining that reclassification would place the Commission on firm footing to protect Americans and partner even more effectively with our sister national security agencies on the same goal Those partners have already asked the FCC to examine all solutions and authority to help secure our networks And gaps in our authority have already manifested and hindered our ability to defend against known threatsppTaken together these Commission actions signal that the agency plans to focus on and take a more active approach to privacy data protection and cyber security issues going forward  While the timing and scope of these new partnerships have not yet crystalized it is worth monitoring the further actions as well as those of its new statebased partners and other agencies like the Federal Trade Commission that operate in this areapp ppSign Up for eNewsBulletinspp ppYou are responsible for reading understanding and agreeing to the National Law Reviews NLRs and the National Law Forum LLCs  Terms of Use and Privacy Policy before using the National Law Review website The National Law Review is a free to use nolog in database of legal and business articles The content and links on wwwNatLawReviewcom are intended for general information purposes only Any legal analysis legislative updates or other content and links should not be construed as legal or professional advice or a substitute for such advice No attorneyclient or confidential relationship is formed by the transmission of information between you and the National Law 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