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FCC Seeks Public Comment on Mobile Carrier Privacy Policies Following Data Collection Controversy

By InfoLawGroup LLP on June 29, 2012

In re-launching the inquiry into carriers' data privacy and security practices, the FCC argues that not informing customers about the software or its data practices may have violated the carriers' responsibility pursuant to Section 222 of the Communications Act of 1934 to protect customer data "that is made available to a carrier solely by virtue of the carrier-customer relationship." The law allows such data to be used only in "limited circumstances," a term which is not defined in Section 222. It appears that one of the goals of the renewed inquiry is for the FCC to define the scope of the "limited circumstances."

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The Legal Implications of BYOD (Part II) - Preparing Personal Device Use Policies

By InfoLawGroup LLP on June 11, 2012

In our last "bring your own device" post we explored some of the key security, privacy and incident response issues related to BYOD. These issues are often important drivers in a company's decision to pursue a BYOD strategy and set the scope of personal device use within their organization. If the risks and costs associated with BYOD outstrip the benefits, a BYOD strategy may be abandoned altogether. One of the primary tools (if not the most important tool) for addressing such risks are BYOD-related policies. Sometimes these policies are embedded within an organization's existing security and privacy policy framework. More frequently, however, companies are creating separate personal device use policies that stand alone or work with/cross-reference existing company security, privacy and incident response polices. This post lays out the key considerations company lawyers and compliance personnel should take into account when creating personal device use policies and outlines some of the important provisions that are often found in such policies.