Deadlines for New FCC Privacy Rules Triggered: Implementation to Begin January 3rd


The Federal Communications Commission’s (FCC) new Privacy Rules have been triggered by publication of the rules in the Federal Register.  The new rules take effect throughout 2017, barring any changes from the FCC during the upcoming year.

The new FCC rules have numerous parts and subparts with which telecommunications carriers and ISPs must become familiar.  Here’s when each of the new rules is slated to come into effect:

Provide Notice to Customers – December 4, 2017*
Obtain Customer Consent – December 4, 2017*
Implement Reasonable Data Security – March 2, 2017
Follow Data Breach Notification Procedures – June 2, 2017*
Take It or Leave It Offer Rules – January 3, 2017
Financial Incentive Rules – December 4, 2017*
All Other Elements of the privacy order – January 3, 2017

*Implementation may take more time for the Paperwork Reduction Act review process.

As a reminder, small ISPs and small voice providers may qualify for a one year extension on implementing the rules on notice and consent.
To assist our clients with implementing the new rules, our firm has prepared a step-by-step guide: the “Comprehensive Guide to Compliance with FCC and FTC Privacy Regulations:  For Service Providers and Vendors in the Internet, Data and Communications Solutions Ecosystem.”  If you are interested in purchasing the Guide, or if you have any questions about the new FCC privacy rules, please contact Linda McReynolds, CIPP/US, at, or 703-714-1318, or Alexander Schneider, at, or 703-714-1328.

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