A Public Notice has been released providing guidance to broadband providers on how the Enforcement Bureau plans to enforce Section 222 of the Act (CPNI Obligations) with regards to broadband Internet access service. As you may recall, Section 222 will apply to broadband providers once the Open Internet Order goes into effect. During the time between the effective date of the Open Internet Order and subsequent Commission guidance on Section 222, the Enforcement Bureau intends to focus on whether providers are taking reasonable, good-faith steps to comply, rather than on technical details. By doing so, the Enforcement Bureau intends that broadband providers should employ effective privacy protections in line with their privacy policies.
In addition, broadband providers may request advisory opinions on their future conduct to ensure compliance with the Open Internet Order.
Please do not hesitate to contact TLP if you have any questions.