EPIC Encourages FCC to Continue Advancing Five Principles to Protect Domestic Violence Survivors in Connected Cars Rulemaking

On May 23, EPIC filed two comments with the Federal Communications Commission regarding its proposed rulemaking on connected cars under the Safe Connections Act: a coalition letter signed by more than 20 civil society organizations outlining five core principles and an extensive comment co-drafted with Public Knowledge outlining specific policy recommendations and sources of legal authority.

The Safe Connections Act tasks the FCC with protecting survivors of domestic violence (DV) from abuse perpetrated by misuse of America’s communications networks. EPIC and its partners continue to support the FCC in these efforts.

The coalition letter emphasized five high-level principles:

1. Connected car systems should support survivor self-determination and agency.
2. The Commission should prioritize program utilization and accessibility over hypothetical fraud concerns.
3. Connected car systems should implement data minimization and data security by default.
4. Connected car systems should proactively prevent misuse.
5. The burden of accessing survivor services should be on manufacturers and providers, not on survivors.

The comment filed in partnership with Public Knowledge elaborated on these five principles, offered recommendations to help the Commission to avoid creating unintentional loopholes, urged the Commission to tailor cybersecurity controls to the unique needs faced by survivors of domestic violence, and outlined the Commission’s authority to enact these rules both within the limits of the Safe Connections Act and outside its limits but within the FCC’s other authorities.

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.