Robocall mitigation plan secrets
USTelecom filed reply comments with the FCC that were sharply critical of recent filings in the Robocall Mitigation Database (RMD) seeking blanket confidentiality for providers’ robocall mitigation plans. Here’s what’s happening.
In their reply comments, USTelecom responded to the FCC Wireline Competition Bureau’s request for comments on a protective order for RMD collection. Here’s is the crux of their complaint:
Recent filings in the RMD seeking blanket confidentiality for providers’ robocall mitigation plans are of deep concern and threaten the transparency and accountability that the RMD is intended to create.
The Bureau should ensure that robocall mitigation plans are public by default, and only truly confidential and sensitive information is withheld from full public view.
USTelecom cites the FCC’s Second Report and Order, which states that the intent of the confidentiality provision is to avoid giving bad actors the information they need to undermine the provider’s programs, or disclose sensitive competitive information.
RMD confidential filings
On June 14, 2021, we reviewed robocall mitigation plans in the RMD for providers that filed a request for confidentiality. Here’s what we found:
- There were 552 robocall mitigation plans filed in the RMD.
- There are 50 redacted plans in the RMD, which is 9% of the plans filed.
- Of the redacted plans, 46 are fully or almost fully redacted, which is 92% of the redacted plans. USTelecom seems to have a point here.
- Of the four partially redacted plans, we found the following redactions:
- One redacted the their robocall mitigation contact name.
- Another redacted the name of an underlying service provider.
- The last two redacted some details of their robocall mitigation methods.
- 41 of the 46 fully redacted plans (89%) were nearly identical in the following respects:
- They had a cover page with the company name
- They had the same table of contents
- After the table of contents, there were 10 pages of fully redacted content.
- The PDF file properties indicate that the source document was written by Doug Eidahl. Searching LinkedIn, we found a Doug Eidahl who works for Vantage Point Solutions in Mitchell, South Dakota.
We’re not sure where this will lead. It seems that USTelecom has raised some fair points. They cited the FCC’s statements from orders that established the RMD. These statements describe the importance of transparency and accountability.
However, the FCC was deliberately non-prescriptive in providing instructions for filing a robocall mitigation plan. Further, they provided a mechanism to request confidentiality.
This will be interesting to watch.
We provide our customers with a robocall mitigation plan template that describes how our robocall mitigation methods work. Our customers use this information in their robocall mitigation plan filing. They may redact parts of their public-facing plan if they wish, but it is not necessary. The robocall mitigation methods are very effective, whether a would-be robocaller knows the details or not.
In addition, we help service providers with all aspects of STIR/SHAKEN deployment, including registering with the Policy Administrator and filing their Robocall Mitigation certification with the FCC.
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