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Jul. 17, 2024

FCC Forfeiture Orders Underline Need for Vigilance on Geolocation Sharing

  • David Hill
    Cybersecurity Law Report
The FCC recently imposed penalties totaling almost $200 million on the leading U.S. wireless carriers, after concluding that they had contravened regulations on sharing customer geolocation data with other businesses. The Forfeiture Orders (Orders) affect Verizon, AT&T and T‑Mobile US – the three big providers – and Sprint, which has since merged into T‑Mobile US. With insights from Squire Patton Boggs partner Eduardo Guzmán and Marashlian & Donahue counsel Linda McReynolds, this article examines the Orders, including the FCC’s definition of customer proprietary network information and treatment of consent, and offers compliance lessons that can be drawn from them regarding the sharing of geolocation data. See “Enforcing Consumer Consent: FTC Focuses on Location Tracking and Children’s Privacy” (Jul. 6, 2016).

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