Comments to the FCC on Open Internet and Broadband


This afternoon we filed comments to the FCC which address their October 22nd 2009 Notice of Proposed Rulemaking (NPRM) focused on “Preserving the Open Internet and Broadband Industry Practices.” The FCC’s request for comments are an important opportunity for us to highlight the fact that Broadband access and use implicates numerous privacy and data security issues. Thus far, much of the conversation surrounding broadband Internet access, has focused on ensuring that service providers do not interfere with user privacy rights, which is an important goal. However, equally important is the goal that the Commission should ensure that any new rules it adopts do not impair broadband Internet access service providers’ ability to protect consumer privacy online. As we state in our comments, “The collection, use, sharing, security, and disposal of personal information occurs at many places on the Internet and often involves numerous parties in the broadband ecosystem. These activities create risks to consumers such as identity theft, and they raise concerns about the unwanted distribution of personal information to unintended recipients. … Consumers only will expand their adoption and usage of broadband services and technologies if they can be confident that there are adequate privacy and data security protections available. Thus, ensuring that broadband Internet access service providers can deploy innovative tools to protect consumers’ personal information and respond to evolving security risks is a critical element in promoting an open Internet and facilitating broadband use.”

To read the full comments click here and here.

Authored by: Jules Polonetsky and Christopher Wolf