# FCC's KYC Proposal: A Threat to Privacy and Anonymity, Not a Solution to Spam Calls The **Federal Communications Commission (FCC)** is pushing a controversial proposal that would require telecommunications providers to implement a Know Your Customer (KYC) protocol for all phone number activations. This move, intended to curb the deluge of unwanted calls, is being met with strong opposition from privacy advocates and cybersecurity experts who argue it's an ineffective solution that poses significant risks to consumer privacy, access to communication, and freedom of speech. ## A Flawed Approach to Combating Spam The **FCC** itself acknowledges in its rulemaking that "the most effective way to prevent unwanted calls from reaching American consumers is by ensuring they never enter the network." Furthermore, the **Federal Trade Commission (FTC)** has found that a significant proportion of unwanted robocalls originate from overseas. Collecting personal information from every U.S. phone user is unlikely to impact these offshore operations. Instead, organizations like the **Electronic Frontier Foundation (EFF)** and the **ACLU** contend that the **FCC** should prioritize full implementation of its existing **STIR/SHAKEN** technical standards. While not perfect, **STIR/SHAKEN** offers a technical solution to call authentication, yet less than 50% of American telecommunication providers have fully adopted it. ## The True Motive: Eradicating Anonymous Phones The **FCC**'s proposal, as outlined in its comments, appears to have a secondary, more concerning objective: the elimination of anonymous phone lines, often referred to as **burner phones**. The commission explicitly states its aim to assist law enforcement in identifying callers for criminal investigations, citing examples related to organized crime and trafficking. However, anonymous phones serve as a crucial lifeline for a diverse range of individuals, including: * Domestic violence and human trafficking survivors * Unhoused individuals * Children without stable homes * Activists and journalists protecting sources * Privacy-conscious consumers Stripping away this anonymity would disproportionately harm vulnerable populations and stifle free expression, without providing an adequate alternative for those in precarious situations. ## Mass Data Collection: A Recipe for Disaster The telecommunications industry has a troubling track record as stewards of personal data, making the prospect of mass data collection a significant cybersecurity and privacy concern. Recent history is rife with examples of major breaches: * In 2024, **AT&T** disclosed two substantial data breaches, one impacting 7.6 million existing and 65 million former customers, and another affecting over 100 million customer call and text logs. * **Comcast** suffered a breach in 2023, exposing data for nearly 36 million account holders, including partial Social Security Numbers and dates of birth. * The nation's **CALEA** infrastructure, used by law enforcement for call tapping, was compromised in the **Salt Typhoon** attacks in 2024, highlighting ongoing vulnerabilities in critical communication networks. These incidents underscore the industry's struggle to secure even the most sensitive information. Furthermore, providers have been accused of misusing customer data. In the case of *Scott v AT&T*, **AT&T** was alleged to have made consumer information available to hundreds of third parties without explicit consent, demonstrating a profound disregard for customer privacy. ## Barriers to Communication and Silencing Voices The **FCC**'s proposed requirements for physical addresses and government-issued identification will create insurmountable barriers for millions of Americans to obtain phone service. Many individuals, including those experiencing homelessness, do not have stable addresses. Moreover, a significant portion of the U.S. adult population lacks government-issued photo ID, with disproportionate impacts on Black and Hispanic Americans, individuals with disabilities, and those with lower incomes. Anonymity in communication is vital for personal safety, political organizing, and accessing critical services such as suicide hotlines, sexual assault support, addiction recovery, and medical care. Removing this anonymity could silence vulnerable individuals and prevent them from seeking essential help or participating freely in society. ## Conclusion The **FCC**'s KYC proposal is a misguided attempt to combat spam calls that will ultimately fail in its stated goal. Instead, it will establish a dangerous mass data collection regime, undermine cybersecurity, strip away fundamental rights to anonymous speech, and disconnect millions of marginalized Americans. The **EFF** strongly urges the **FCC** to abandon this proposal entirely. The window for reply comments remains open until July 26th, offering individuals an opportunity to express their concerns.