EPIC, Coalition Urge FCC to Combat Stalkerware and Police Misuse of Survivor Data in Safe Connections Rulemaking

April 15, 2023

On April 12, EPIC, the National Network to End Domestic Violence (NNEDV), and more than 10 other survivor advocacy and direct service organizations filed comments to the Federal Communications Commission regarding its implementation of the requirements of the Safe Connections Act of 2022. The rulemaking seeks to help survivors of domestic violence separate their phone line from a shared account with an abuser, to protect the privacy of calls with hotlines and shelters, and to support survivors experiencing financial hardship through affordability programs.

The coalition voiced support for the FCC’s emphasis on survivor self-determination and agency as well as the FCC’s consideration for minimizing burdens and barriers for survivors, including proposing a presumption of financial hardship rather than requiring survivors to demonstrate financial hardship. This is significant because it can be difficult for survivors to obtain documents in their abuser’s control and because there may be variance between what resources a survivor actually has access to and what their assets appear to be on paper.

The coalition also called upon the FCC to prioritize data minimization and require data security best practices when data retention is necessary, as exposure of data about survivors can lead to life-threatening risks. Similarly, the coalition urged the FCC to put safeguards in place to prevent misuse of law enforcement access to survivor data, as personal misuse of access to databases by law enforcement personnel is a well-documented phenomenon.

EPIC, NNEDV, and its sign-on partners also urged the FCC to give phone carriers guidance in how to support survivors with phone device-related privacy and safety concerns, such as stalkerware, a concern the FCC included in this rulemaking as a result of the advocacy of EPIC and its partners at the Notice of Inquiry stage.

EPIC advocates for laws, regulations, and policies that safeguard user privacy and protect users from technology-facilitated abuse and harassment, including actions against stalkerware developers. EPIC also filed an amicus brief urging that dating platform companies be held liable when they ignore harassment and abuse.

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