The American Library Association (ALA) sent a letter to the FCC expressing concern over Emergency Connectivity rule (§ 54.1715) that requires all ECF program related documentation be retained for ten years and the rule stating that participants may produce records regarding students, school staff, and library patrons in an anonymized or deidentified format (§ 54.1714(c)) to comply with federal or state privacy laws.
In the letter, ALA states,”…Specifically, libraries have reported that the rules related to (1) patron data and (2) the ten-year documentation requirement of that data constitute significant barriers to participation in the ECF program, both in terms of library policy and practice. To maximize library participation, especially among small, rural, and tribal libraries, we ask the Commission to consider how it might further mitigate the impact on patron privacy policies while still meeting the regulations in the ECF order…”
The letter outlines a scenario to operate with the data retention requirement. The letter further asks the FCC to delay enforcing this requirement for 90 days, to November 13, after the application window closes on August 13. This modest delay will help libraries and schools to develop a system or process for retaining the required information.
The American Library Association letter to FCC can be viewed here
