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FAQs - Form 477 Data Sharing with Eligible Entities

These Frequently Asked Questions (FAQs) are provided to clarify certain aspects of Form 477 data sharing with state-designated mapping grant recipients  or “eligible entities.”  They are not a substitute for the requirements in the Eligible Entities Aggregate Form 477 Data Order but are intended to provide guidance in determining how to comply with those requirements.  Eligible Entities with additional questions may send them to 477sharing@fcc.gov.

Regarding the provision in para. 42 of the Order (which provides that, once loaded into a computer, the files containing aggregated data shall be password protected immediately), is it sufficient to implement password protection on the device(s) used to access the data, or is there a separate requirement to password protect the files?

Because the Order expressly requires password protection for the files, mere reliance on password protection for the computer does not appear to be sufficient. (last updated: June 8, 2010)

May the aggregated data be stored on a networked computer provided that the files containing the data are not copied, or does the Order require that the aggregated data be stored on an off-network PC?

The Order bars storage of the aggregated data in computer memory that is copied, such as to a network’s back-up or archival storage. It does not expressly require that the aggregated data be stored on an off-network PC. (last updated: June 8, 2010)

Does the analysis that makes use of the aggregated data have to be stored on a mobile data storage medium, or can it be stored on a networked computer (provided it is not copied)?

Paragraph 42c of the Order provides, “After the analysis is complete, the results of such analysis may be stored by saving the results (but not the underlying aggregate data) to a mobile data storage medium…” (emphasis added). Thus, the Order does not appear to bar storing the analysis on a networked or stand-alone computer in the same manner that the underlying aggregate data is stored. (last updated: June 8, 2010)

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