FCC Record, Volume 27, No. 7, Pages 5674 to 6652, May 23 - June 15, 2012 Page: 5,745
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safeguarding and erasing that information before disposal or recycling the
Sprint similarly stated in 2007 that "[w]ireless carriers are not well-positioned to guarantee the
privacy of customer information stored on devices" because those devices are manufactured by
suppliers and "in the physical control and custody of customers."9
In recent months, it has become clear that these submissions are badly out of date.
Mobile carriers are directing the collection and storage of customer-specific information on
mobile devices. In response to questions from Congress concerning its use of "Carrier IQ"
software, AT&T explained that it gathers customer-specific data as an "enhance[ment of] its
network reporting capabilities" and to collect information about its network from the perspective
of its users' devices, "a view that cannot be obtained from the network alone."' Answering the
same questions, Sprint identified a "legitimate need to deploy and use diagnostic software in the
maintenance and operation of [Sprint's] services" and described how Sprint worked with the
software vendor to customize data collection for Sprint's devices and network." T-Mobile
likewise stated that it uses software on its customers' mobile devices to "assist T-Mobile in
improving our customers' wireless experience by capturing and analyzing a narrow set of data
related to some of the most common issues our customers experience."2 The data collected in
this manner may be shared with a third party for purposes of network diagnostics or improving
$ Comments of AT&T Inc., CC Docket No. 96-115 (July 9, 2007), at 9, available at
9 Comments of Sprint Nextel Corporation, CC Docket No. 96-115 and WC Docket No. 04-36, at 21 (July
9, 2007), available at http://apps. fcc.ov!ecfs'documentiview?id=6519548080; see also Reply Comments
of Sprint Nextel Corporation, CC Docket No. 96-115 and WC Docket No. 04-36, at 14 (Aug. 7, 2007)
("Importantly, none of the information (e.g. songs, photographs and address books) stored on a handset is
CPNI and thus [it] is not addressed by section 222 of the Act."), available at
'0 AT&T Letter to Sen. Franken at 1; see also id at 5 (stating that this activity is covered by provisions in
network, performance, and usage information from our network and customer devices").
" Sprint Letter to Sen. Franken at 1.
12 T-Mobile Letter to Sen. Franken at 1-2.
13 See Carrier IQ, Understanding Carrier IQ Technology: What Carrier IQ Does and Does Not Do (Dec.
15, 2011), at 13, available at http://www .carrieriq.corn/documents/understanding-carrier-iq-
technology/646 I /(last visited May 24, 2012) (stating that Carrier IQ hosts servers on behalf of some
customers, while other customers host servers in their own data centers); AT&T Letter to Sen. Franken at
3 (stating that AT&T hosts its own servers); Sprint Letter to Sen. Franken at 2 (stating that data is
transmitted to Carrier IQ servers); T-Mobile Letter to Sen. Franken at 4-5 (stating that data is stored on
dedicated servers by Carrier IQ and its subcontractors).
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United States. Federal Communications Commission. FCC Record, Volume 27, No. 7, Pages 5674 to 6652, May 23 - June 15, 2012, book, June 2012; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc111171/m1/88/: accessed March 23, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.