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Confidentiality for IP CTS Consumers' Personal Information

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Released: December 2, 2013


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 13-2300

Released: December 2, 2013




CG Docket Nos. 13-24 & 03-123

The Federal Communications Commission’s (FCC or Commission) Consumer and Government
Affairs Bureau (Bureau) understands that some IP CTS providers have received inquiries regarding the
need to collect personal information from consumers wishing to register for Internet Protocol Captioned
Telephone Service (IP CTS), and the extent to which such information will be kept confidential.1 To
guard against TRS fraud, abuse, and waste, in August 2013, the FCC adopted regulations requiring
consumers who are registering for IP CTS to provide the following information to their IP CTS providers:
full name, date of birth, address, telephone number, and the last four digits of the consumer’s social
security number.2 Each IP CTS provider must obtain this information from all users of IP CTS,
regardless of when these individuals began receiving these relay services.3 In addition, consumers must
certify that, among other things, they have a hearing loss that necessitates IP CTS to communicate by

1 IP CTS is a form of telecommunications relay service (TRS) that permits an individual who can speak but who has
difficulty hearing over the telephone to use a telephone and an Internet Protocol-enabled device to simultaneously
listen to the other party and read captions of what the other party is saying. With IP CTS, the connection carrying
the captions between the relay service provider and the relay service user is via the Internet, rather than the public
switched telephone network. 47 C.F.R. § 64.601(12).
2 47 C.F.R. § 64.604(c)(9)(i). See also Misuse of Internet Protocol (IP) Captioned Telephone Service;
Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
CG Docket Nos. 13-24 and 03-123, Report and Order and Further Notice of Proposed Rulemaking, 28
FCC Rcd 13420, 13449, ¶ 64, 13452, ¶ 69 (2013) (IP CTS Reform Order).
3 47 C.F.R. § 64.604(c)(9)(i), (xi).
4 47 C.F.R. § 64.604(c)(9)(ii)-(xi). We note that recently adopted regulations governing the provision of video relay
service (VRS), a form of TRS that allows people with disabilities who use sign language to communicate with voice
telephone users through video equipment and communication assistants (47 C.F.R. § 64.601 (27)), similarly require
providers to obtain such personal information as part of the registration and certification of VRS users. 47 C.F.R.
§ 64.611(a)(4). See also Structure and Practices of the Video Relay Services Program; Telecommunications Relay
Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities
, CG Docket Nos. 10-
51 and 03-123, Report and Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd 8618, 8650, ¶ 70 (2013)
(VRS Structural Reform Order). The required information, including the last four digits of the social security
number or Tribal Identification number, if the registered Internet-based TRS user is a member of a Tribal nation and
does not have a social security number, is generally comparable to information required for registration with the
FCC’s Lifeline program. See 47 C.F.R. § 54.410(d)(2).

We take this opportunity to reaffirm that, under FCC regulations, IP CTS providers must maintain
the confidentiality of the personal information obtained from consumers through their registration and
certification. Specifically, Commission regulations require that each IP CTS provider “maintain the
confidentiality of . . . registration and certification information” and prohibit VRS and IP CTS providers
from “disclos[ing] such registration and certification information or the content of such registration and
certification information except as required by law or regulation.”5
The full text of this Public Notice is available for public inspection and copying during regular
business hours at the FCC Reference Information Center, Portals II, 445 12th Street, SW, Room CY-
A257, Washington, DC, 20554. This document may be purchased from the Commission's duplicating
contractor, Best Copy and Printing, Inc., Portals II, 445 12th Street, SW, Room CY-B402, Washington,
DC 20554. Customers may contact BCPI at their web site: or call 1-800-378-3160.
To request this document in accessible formats for people with disabilities (braille, large print,
electronic files, audio format), send an e-mail to or call the Consumer & Governmental
Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (TTY). This Public Notice can also be
downloaded in Word and Portable Format at .
For further information, please contact Cheryl King, Consumer and Governmental Affairs
Bureau, Disability Rights Office, at (202) 418-2284 or e-mail at

5 47 C.F.R. § 64.611(a)(3)(iv). The requirement to maintain the confidentiality of a registered relay user’s personal
information also applies to information provided by registered VRS users. 47 C.F.R. § 64.604(c)(9)(x).

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