# Supporting Survivors of Domestic and Sexual Violence; Lifeline and Link Up Reform Modernization > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/fr%3A2023-25835 ## Record - **Collection:** Federal Register - **Document type:** Rule - **Published:** December 5, 2023 - **Citation:** 88 FR 84406 ## Text FEDERAL COMMUNICATIONS COMMISSION 47 CFR Parts 54 and 64 [WC Docket Nos. 22-238, 11-42, 21-450; FCC 23-96, FR ID 183619] Supporting Survivors of Domestic and Sexual Violence; Lifeline and Link Up Reform Modernization AGENCY: Federal Communications Commission. ACTION: Final rule. SUMMARY: In this document, the Federal Communications Commission adopted a Report and Order implementing the Safe Connections Act of 2022 (Safe Connections Act or SCA), taking significant steps to improve access to communications services for survivors of domestic abuse and related crimes. The Report and Order adopts rules to implement the line separation provisions in the Safe Connections Act that allow survivors to separate a mobile phone line from an abuser. To protect the privacy of calls and texts to hotlines, the Report and Order requires covered providers and wireline, fixed wireless, and fixed satellite providers of voice service to: omit from consumer-facing logs of calls and text messages any records of calls or text messages to covered hotlines in the central database established by the Commission; and maintain internal records of calls and text messages excluded from consumer-facing logs of calls and text messages. The Report and Order also designates the Lifeline program to support emergency communications service for survivors that have pursued the line separation process and are experiencing financial hardship. DATES: Effective date: This rule is effective January 14, 2024. Compliance date: Compliance with the revisions to 47 CFR 54.403, 54.405, 54.409, 54.410, 54.1800, and 64.2010 and the addition of 47 CFR 54.424 and 64.6400 through 64.6407 is delayed indefinitely. The FCC will publish a document in the Federal Register announcing the compliance date for those sections. ADDRESSES: Federal Communications Commission, 45 L Street SW, Washington, DC 20554. In addition to filing comments with the Office of the Secretary, a copy of any comments on the Paperwork Reduction Act information collection requirements contained herein should be submitted to Nicole Ongele, Federal Communications Commission, 45 L Street SW, Washington, DC 20554, or send an email to PRA@fcc.gov . FOR FURTHER INFORMATION CONTACT: For further information, contact Melissa Kirkel at melissa.kirkel@fcc.gov or 202-418-7958 or Nicholas Page at nicholas.page@fcc.gov or 202-418-2783. For additional information concerning the Paperwork Reduction Act information collection requirements contained in this document, send an email to PRA@fcc.gov or contact Nicole Ongele, Nicole.Ongele@fcc.gov . SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Report and Order in WC Docket Nos. 22-238, 11-42, and 21-450, FCC 23-96, adopted on November 15, 2023, and released on November 16, 2023. The full text of the document is available on the Commission's website at https://docs.fcc.gov/public/attachments/FCC-23-96A1.pdf . To request materials in accessible formats for people with disabilities ( e.g., braille, large print, electronic files, audio format, etc.), send an email to FCC504@fcc.gov or call the Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice). Compliance with the rule changes adopted in the Report and Order, except for § 64.6408, shall not be required until the later of: (i) six months after the effective date of the Report and Order ; or (ii) after the Office of Management and Budget (OMB) completes review of any information collection requirements associated with the Report and Order that the Wireline Competition Bureau determines is required under the Paperwork Reduction Act. With respect to covered providers, wireline providers of voice service, fixed wireless providers of voice service, and fixed satellite providers of voice service that are not small service providers, compliance with 47 CFR 64.6408(a) shall be required December 5, 2024. In the event the Wireline Competition Bureau has not released the database download file specification by April 5, 2024, or in the event the Wireline Competition Bureau has not announced that the database administrator has made the initial database download file available for testing by October 7, 2024, the compliance deadline shall be extended consistent with the delay, and the Wireline Competition Bureau is delegated authority to revise 47 CFR 64.6408 accordingly. With respect to small service providers that are covered providers or wireline providers of voice service, compliance with 47 CFR 64.6408(a) shall be required June 5, 2025. In the event the Wireline Competition Bureau has not released the database download file specification by October 7, 2024, or in the event the Wireline Competition Bureau has not announced that the database administrator has made the initial database download file available for testing by April 7, 2025, the compliance deadline set forth in this paragraph shall be extended consistent with the delay, and the Wireline Competition Bureau is delegated authority to revise 47 CFR 64.6408 accordingly. Paperwork Reduction Act of 1995 Analysis This document contains new or modified information collection requirements. The Commission, as part of its continuing effort to reduce paperwork burdens, invites the general public to comment on the information collection requirements contained in the Report and Order as required by the Paperwork Reduction Act of 1995, Public Law 104-13. In addition, the Commission notes that pursuant to the Small Business Paperwork Relief Act of 2002, Public Law 107-198, see 44 U.S.C. 3506(c)(4), we previously sought specific comment on how the Commission might further reduce the information collection burden for small business concerns with fewer than 25 employees. In the Report and Order, we adopt rules, pursuant to Congress's direction in the SCA, that have an impact on all covered providers, including covered providers that are small entities. We impose certain obligations regarding communications with consumers and survivors. We also establish a compliance date six months after the effective date of the Report and Order, finding that the countervailing public interest in ensuring survivors have access to line separations regardless of their provider outweighs an extended compliance deadline for small covered providers. Further, staggered compliance deadlines could cause confusion for consumers, and we believe that the SCA's operational and technical infeasibility provisions we codify in our rules will account for differences in the capabilities between large and small covered providers regarding information collection requirements. Regarding protecting the privacy of calls and texts to hotlines, we require covered providers and wireline providers of voice service, within 12 months, subject to certain conditions that may extend this time, (1) omit from consumer-facing logs of calls and text messages any records of calls or text messages to covered hotlines in the central database established by the Commission; and (2) maintain internal records of calls and text messages excluded from consumer-facing logs of calls and text messages. Covered providers and wireline providers of voice service that are small service providers are given 18 months, subject to certain conditions that may extend this time, to comply with the same obligations. We received comments requesting that smaller providers be afforded 24 months to comply with such obligations. Recognizing that the SCA contains no language regarding specific timeframes with respect to this obligation, we found that granting smaller providers extra implementation time is appropriate, given that they may face more resource challenges than larger providers in complying with the new rules. We acknowledged that this 18-month period is less than the requested 24-month period, but we found that our 18-month compliance deadline for small providers properly balances the significance of the risks faced by domestic abuse survivors, and the benefits of them being able to call hotlines and seek help without fear of the abuser accessing their call records, with the implementation challenges faced by smaller providers. Third, regarding emergency communications support for survivors, we designate the Lifeline program as the program that will support emergency communications efforts for survivors with financial hardship. This will have an impact on eligible telecommunications carriers designated to provide Lifeline support, but we expect any new regulatory impacts to be minor and consistent with our existing rules. As the SCA has no definition for financial hardship we adopt a definition that is more expansive than the current Lifeline eligibility standards, and we adopt an approach for documenting that financial hardship that allows for self-certification. We also direct the Universal Service Administrative Company (USAC) to prepare for a program evaluation of our efforts to provide emergency communications support to survivors. This evaluation will require surveys of relevant stakeholder groups that USAC will develop under the oversight of the Bureau and the Office of Economics and Analytics. The Commission has determined, and the Administrator of the Office of Information and Regulatory Affairs, Office of Management and Budget, concurs, that this rule is non-major under the Congressional Review Act, 5 U.S.C. 804(2). The Commission will send a copy of the Report and Order to Congress and the Government Accountability Office pursuant to 5 U.S.C. 801(a)(1)(A). Synopsis I. Discussion A. Separation of Lines From Shared Mobile Service Contracts 1. We adopt rules to codify and implement the line separation provisions in the Safe Connections Act of 2022, Public Law 117-223, 116 Stat. 2280. Our rules largely track the statutory language, with key additions and clarifications to address privacy, account security, and fraud detection; operational or technical infeasibility; implementation timelines; and compliance with other laws. 1. Definitions 2. In order to implement the SCA's line separation requirements, we adopt definitions for the terms listed in new section 345 of the Communications Act, as added by the SCA, including “covered act,” “survivor,” “abuser,” “covered provider,” “shared mobile services contract,” and “primary account holder.” We discuss each definition below. 3. Covered Act. As proposed in the “Supporting Survivors of Domestic and Sexual Violence, Lifeline and Link Up Reform and Modernization, Affordable Connectivity Program” notice of proposed rulemaking (NPRM), 88 FR 15558 (March 13, 2023) ( Safe Connections NPRM ), we define “covered act” as conduct that constitutes (1) a crime described in section 40002(a) of the Violence Against Women Act of 1994 (34 U.S.C. 12291(a)), including, but not limited to, domestic violence, dating violence, sexual assault, stalking, and sex trafficking; (2) an act or practice described in paragraph (11) or (12) of section 103 of the Trafficking Victims Protection Act of 2000 (22 U.S.C. 7102) (relating to severe forms of trafficking in persons and sex trafficking, respectively); or (3) an act under State law, Tribal law, or the Uniform Code of Military Justice that is similar to an offense described in clause (1) or (2) of this paragraph. 4. As we noted in the Safe Connections NPRM, this definition is identical to the statutory definition, except that we add the phrase “but not limited to” in describing the crimes covered by the first clause. Although the SCA defines “covered act” as “a crime described” in section 40002(a) of the Violence Against Women Act “including domestic violence, dating violence, sexual assault, stalking, and sex trafficking,” it does not say that only those listed crimes may be included. Section 40002(a) of the Violence Against Women Act of 1994 describes a number of additional crimes and abuses beyond those enumerated in the SCA's definition, including abuse in later life, child abuse and neglect, child maltreatment, economic abuse, elder abuse, female genital mutilation or cutting, forced marriage, and technological abuse. We find that the best reading of the definition of “covered act” in the SCA includes all crimes listed in section 40002(a); we see no reason why Congress would choose to protect only a subset of survivors of these crimes. We further find that the second clause of the definition of “covered act” in the SCA, which identifies specific subsections (“an act or practice described in paragraph (11) or (12) of Section 103 of the Trafficking Victims Protection Act of 2000”) also supports our analysis because in contrast, the first clause of the definition of “covered act” does not limit the definition to specific subsections of section 40002(a) of the Violence Against Women Act. 5. Consistent with the SCA, we conclude that a criminal conviction or any other determination of a court is not required for conduct to constitute a covered act. The SCA separately addresses the evidence needed to establish that a covered act has been committed or allegedly committed. We address those requirements below. 6. Survivor. We track the statutory language and define “survivor” as an individual who is not less than 18 years old and either (1) against whom a covered act has been committed or allegedly committed; or (2) who cares for another individual against whom a covered act has been committed or allegedly committed (provided that the individual providing care did not commit or allegedly commit the covered act). Although we share the concerns raised by Asian Pacific Institute on Gender-Based Violence (API-GBV) and the National Domestic Violence Hotline (NDVH) that emancipated minors would not be covered by the statutory definition because they are neither age 18 or older nor likely to be in the care of an individual age 18 or older, the term “survivor” is unambiguously defined by the SCA to only include “individual[s] who [are] not less than 18 years old,” and we do not believe that the SCA otherwise provides us with the authority to extend the scope of that definition. Regardless, we strongly encourage covered providers to treat legally emancipated minors as though they are survivors if they meet the SCA's criteria but for their age, and offer them the full scope of protections under the SCA. 7. As we observed in the Safe Connections NPRM, the statutory language describing a survivor as an individual “who cares for another individual” against whom a covered act has been committed or allegedly committed is broad. We conclude that this phrase should be understood to encompass: (1) any individuals who are part of the same household, as defined in § 54.400 of the Commission's rules (47 CFR 54.400(h)); (2) parents or guardians of minor children even if the parents and children live at different addresses; (3) those who care for another individual by valid court order or power of attorney; and (4) an individual who is the parent, guardian, or caretaker of a person over the age of 18 upon whom an individual is financially or physically dependent. The record generally supports a broad interpretation of the phrase “who cares for,” while noting the need to provide clear and certain guidance to providers. We disagree with the NDVH's assertion that our proposed interpretation would have prevented a person who does not live in the same household from claiming survivor status if a covered act were not directly committed against them, but we nonetheless make explicit that we interpret this provision to include those individuals who are the parent, guardian, or caretaker of a person over the age of 18 upon whom an individual is financially or physically dependent ( e.g., a non-minor child financially dependent on his or her parents or guardians, but who no longer lives at the same address). We find that this interpretation appropriately balances the needs of survivors to have meaningful access to line separations and clarity for providers for administrability and fraud deterrence. 8. We decline, however, to adopt NDVH's proposal to include emotional care within the meaning of “care for” as we find that doing so would be difficult to administer and could raise account security risks. The record does not evince any examples of laws or regulations in which the phrase “cares for” is used to connote emotional caring, and as such we have no basis for finding that Congress intended this provision to be interpreted to include such circumstances. 9. We decline to mandate that covered providers establish a process for individuals age 18 or older who are considered in the care of another person to object to a line separation request made on their behalf. We agree with Verizon that an objection process could “hinder a wireless provider's ability to timely effectuate [a line separation request] within the two-business day period, put the wireless provider in an untenable position of uncertainty as to whether an otherwise valid line separation request should move forward, or both.” 10. Abuser. As proposed in the Safe Connections NPRM, we define “abuser” for purposes of our rules as an individual who has committed or allegedly committed a covered act against (1) an individual who seeks relief under section 345 of the Communications Act and the Commission's implementing rules; or (2) an individual in the care of an individual who seeks relief under section 345 of the Communications Act and the Commission's implementing rules, mirroring the substance of the SCA. No commenters objected to our proposed definition. As we explained in the Safe Connections NPRM, we do not intend our definition to serve as independent evidence of, or establish legal liability in regards to, any alleged crime or act of abuse, and adopt this definition only for purposes of implementing the SCA. 11. Covered Provider. Consistent with the SCA, we define “covered provider” as a provider of “a private mobile service or commercial mobile service, as those terms are defined in 47 U.S.C. 332(d).” No commenters objected to the Safe Connections NPRM' s proposal to adopt such a definition. Section 332(d) defines “commercial mobile service” as “any mobile service (as defined in [47 U.S.C. 153]) that is provided for profit and makes interconnected service available (A) to the public or (B) to such classes of eligible users as to be effectively available to a substantial portion of the public, as specified by regulation by the Commission,” and defines “private mobile service” as “any mobile service (as defined in [47 U.S.C. 153]) that is not a commercial mobile service or the functional equivalent of a commercial mobile service, as specified by regulation by the Commission.” We find that the line separation obligations apply to all providers of commercial mobile service or private mobile service, as the Commission might interpret and apply those definitions, regardless of the underlying technology used to provide the service ( e.g., whether provided through land, mobile, or satellite stations). 12. Consistent with the Commission's proposal, we conclude that covered providers include both facilities-based mobile network operators and resellers/mobile virtual network operators (MVNOs). No commenters objected to this proposal, and several concurred. The record indicates that for some MVNOs, the underlying facilities-based provider may have control over some parts of, or all of, the systems and infrastructure necessary to effectuate line separations. Therefore, we find that to the extent that an MVNO relies upon an underlying facilities-based provider to effectuate line separations, the MVNO should fulfill its obligations under the SCA and our rules through its contractual relationship with the underlying facilities-based provider and may satisfy its obligations by utilizing the same procedures and processes the facilities-based provider makes available to its own customers. However, to the extent an MVNO controls any facilities or systems (for example, customer care or billing), the obligations imposed by the SCA fall entirely upon the MVNO and not the underlying facilities-based provider. 13. Additionally, we conclude that the statutory definition of “covered provider” includes a provider of mobile broadband-only or mobile text service that does not also offer mobile voice service, if such provider assigns a telephone number to a device. Because the SCA defines a “covered provider” to include any provider offering private mobile service or commercial mobile service, we conclude that providers offering data-only mobile service or text-only mobile services ( i.e., no voice services) are “covered providers.” We therefore disagree with National Lifeline Association's suggestion that mobile broadband providers who do not offer mobile voice service should not be considered covered providers, as such providers are statutorily covered by the SCA as providers of private mobile service. 14. Shared Mobile Service Contract. Consistent with the Commission's proposal in the Safe Connections NPRM, we define “shared mobile service contract” as a mobile service contract for an account that includes not less than two lines of service and does not include enterprise services offered by a covered provider, mirroring the definition set forth in the SCA, except that we interpret “2 consumers” to mean “two lines of service.” As the Commission explained in the Safe Connections NPRM, “[i]t is our understanding that mobile service contracts are typically structured around the number of lines of service associated with an account rather than the number of consumers .” As a result of this contract structure, providers may not have information about any users other than the primary account holder and are therefore unlikely to be able to determine whether an account is a shared mobile service contract ( i.e., has two or more consumers). Our interpretation, however, resolves this issue without requiring providers to collect additional information about each user of a multi-line account, and the record supports our approach. CTIA—The Wireless Association (CTIA) commented that our definition “will help enable program success because it generally aligns with providers' customer service and billing systems” and that “adopting a definition focused on `lines of service' rather than `consumers' will avoid impediments to survivors' ability to obtain line separations,” particularly when providers do not know the identity of each consumer associated with an account. Notably, there were no objections to this proposed definition in the record. Furthermore, we find that the operational language of the SCA supports our interpretation, as it requires providers to separate particular lines rather than particular consumers from shared mobile service contracts. Consistent with the tentative conclusion in the Safe Connections NPRM, we also find that “shared mobile service contract” includes both prepaid and post-paid mobile service contracts. This tentative conclusion was also unopposed and supported by CTIA. 15. We also conclude that a “line of service” under a shared mobile service contract is one that is associated with a telephone number, even if that line of service does not include voice services, and includes all of the mobile services associated with that line under the shared mobile service contract, regardless of classification, including voice, text, and data services. There is nothing in the statutory text to suggest that Congress intended to permit survivors to separate only certain services associated with their line but not others. Each service—voice, text, or data—could play a vital role in addressing survivors' communications needs. For example, although a device may lack voice service or capability over commercial mobile radio service, if a phone number is associated with the device, a survivor may use the number with certain over-the-top (OTT) services to send and receive messages or make voice calls by utilizing Voice over internet Protocol (VoIP) technology using data services or data messaging services. Such OTT services may include, for example, applications like WhatsApp, Signal, Messenger, and Telegram. Permitting separation of such lines may help avoid complications that could arise from disassociating with an existing number for these services. Had Congress wanted to limit line separations to only those lines with voice service, it could have done so explicitly in the statutory text. Congress, however, noted that “perpetrators of violence and abuse increasingly use technological and communications tools to exercise control over, monitor, and abuse their victims.” Clearly, Congress recognized that abusers might try to exercise control over survivors not only by limiting access to or monitoring devices with voice services but also by controlling other technological and communications tools. Because Congress sought to promote “reliable communications tools to maintain essential connections with family, social safety networks, employers, and support services,” we see no reason to limit the definition of “line of service” to only those lines with voice service when so doing could impede a survivor's access to certain devices and hamper their ability to gain support and services they need. 16. We disagree with Verizon's assertion that “it is far from clear that Congress intended certain other devices,” such as tablets with no mobile capability, which only “nominally” have a line associated with a customer account, to be covered by the SCA. Denying a survivor the ability to separate a line simply because it is “nominally” associated with a device could allow an abuser to maintain control over or monitor the line and the device associated with line and inhibit a survivor's ability to break free from an abusive situation. For example, a survivor may want to separate a line for a device in order to protect his or her location information from an abuser with access to the shared mobile account information. Had Congress wanted to limit line separations in the manner Verizon suggests, Congress could have explicitly done so. However, Congress defined a shared mobile service contract as a mobile service contract that includes not less than two “consumers”—it did not in any way cabin “consumer” to a particular type of mobile service. Therefore, rather than “being far from clear,” it would seem counter to congressional intent to disallow a survivor's line separation request because the line at issue is only “nominally” associated with a device. 17. We also disagree with Verizon's assertion that covered providers are not statutorily required to (but may voluntarily) separate more than one line per survivor on the basis that Congress intended to limit separations to one line per survivor because “the statute uses the term `line' in the singular, not plural.” As an initial matter, we read the statutory language in subsection (b) as framing the process to address each discrete line separation request, which grammatically requires the use of “line” in the singular, and in no way limits the number of lines for which a survivor may seek separation. Furthermore, limiting a survivor to one line separation request could potentially allow an abuser to maintain control over or monitor the survivor's other lines (or devices connected to other lines) that remain on the shared contract. We believe this would be contrary to Congress's goals, particularly of helping survivors establish “independent access to a wireless phone plan.” We also believe that had Congress intended to allow only one line separation per survivor (and one line per each individual in the care of a survivor), it would have made this limitation clear in the text. For example, instead of using the term “the line,” Congress could have said that a provider must “separate one line of the survivor, and one line of any individual in the care of the survivor.” Alternatively, Congress could have expressly limited the number of separations by stating that “a survivor is entitled to one line separation for the survivor and one line separation for each individual in the care of the survivor.” Moreover, the statute uses the exact same term “the line” when discussing the separation of an abuser's line as it does when discussing the separation of a survivor's line. Accepting Verizon's statutory interpretation would mean that a survivor is limited to separating only one line of the abuser's from the shared account. We do not believe that Congress intended to limit a survivor's ability to completely remove an abuser from a shared mobile service contract when so doing would likely impair the survivor's ability to establish independent wireless communications and leave the abusive situation. For all these reasons, we disagree with Verizon's assertion and conclude that covered providers must separate multiple lines, when applicable. 18. The SCA's definition of “shared mobile service contract” explicitly excludes “enterprise services.” Consistent with the Commission's proposal in the Safe Connections NPRM, we conclude that enterprise services are those products or services that are not ordinarily available to mass market customers and are primarily offered to entities to support and manage business operations, which may provide greater security, integration, support, or other features than are ordinarily available to mass market customers, and excludes services marketed and sold on a standardized basis to residential customers and small businesses. Our conclusion is consistent with the Commission's past findings that mass market services are those that are generally “marketed and sold on a standardized basis to residential customers [and] small businesses” whereas enterprise services are “typically offered to larger organizations through customized or individually negotiated arrangements.” 19. Although we appreciate industry concerns over fraud, we decline to create a presumption that wireless accounts listing a business entity as the primary account holder are “enterprise” accounts. We find the concerns of the NCTA—The internet & Television Association (NCTA) that business accounts will be greater targets for fraud without a presumption that all accounts with a business listed as the primary account holder are enterprise accounts or a presumption that any account for which a party has subscribed to a “business wireless service” is an enterprise account to be overstated. The SCA includes adequate safeguards against the type of potential enterprise account fraud raised by NCTA by requiring survivors to submit documentation along with a line separation request demonstrating that an “abuser” who uses a line under the shared mobile service contract has committed or allegedly committed a covered act against the survivor ( i.e., the person requesting the line separation) and an affidavit that the survivor is the user of the specific line. In practical terms, we expect that it would be challenging for a bad actor to make this required showing where the account holder is a business, and not an individual, unless the abuser's name is also the business name on the account. We believe this required showing will minimize the potential for fraud on business accounts. As such, we decline to adopt the CTIA and NCTA suggested presumptions. 20. Primary Account Holder. Finally, as proposed in the Safe Connections NPRM, we define “primary account holder” as “an individual who is a party to a mobile service contract with a covered provider,” mirroring the definition in the SCA. While no commenters opposed this proposal, Verizon noted that “accounts typically have one named account owner,” and explained that “the possibility that `more than a single individual [may be] a party to a mobile service contract' should not affect how the SCA is implemented in practice.'” As such, we see no need to depart from the statutory definition of primary account holder. 2. Submission of Line Separation Requests 21. In this section, we adopt rules to clarify the requirements for submission of a line separation request under section 345 of the Communications Act. We largely codify the requirements set out in the SCA for how survivors submit line separation requests while adopting some measures that clarify those requirements pursuant to the SCA's command that we consider various factors when enacting regulations for the line separation requirement. In particular, the SCA requires the Commission to consider, among other things, privacy protections; account security and fraud detection; the requirements for remote submission of line separation requests, including submission of verification information; feasibility of remote options for small covered providers; compliance with customer proprietary network information (CPNI) requirements; and ensuring covered providers have the necessary account information to comply with the SCA and our rules. Our aim is to maximize survivors' ability to obtain line separations by ensuring that covered providers have clear direction on their obligations related to the submission of line separation requests. Specifically, we establish requirements regarding the information that survivors must submit to request a line separation and the options providers must give survivors when survivors are making a line separation request, taking into account flexibility for survivors wherever possible. We recognize that there may be some instances in which a survivor may wish to separate an abuser's line but is not able to identify the phone number of the abuser that is associated with the account. We expect that in these instances, covered providers will work with survivors to separate the lines of the survivor and those in the survivor's care from the account. a. Information Required To Submit Line Separation Requests 22. The rules we adopt concerning the information that survivors must submit to make a line separation request are closely aligned with the requirements set out in the SCA. Specifically, we require that a survivor's line separation request: (1) state that the survivor is requesting relief from the covered provider under section 345 of the Communications Act and our rules; (2) identify each line that should be separated using the phone number associated with the line; (3) regardless of which lines will be separated, identify which line(s) belong to the survivor and state that the survivor is the user of those lines; (4) when a survivor is seeking separation of the line(s) of any individual under the care of the survivor, include an affidavit setting forth that any such individual is in the care of the survivor and is the user of the specific line; (5) when a survivor is seeking separation of the abuser's line, state that the abuser is the user of that specific line; and (6) include documentation that verifies that an individual who uses a line under the shared mobile service contract ( i.e., an “abuser”) has committed or allegedly committed a covered act against the survivor or an individual in the survivor's care. We also require that a line separation request include the name of the survivor and the name of the abuser that is known to the survivor, which may assist covered providers' fraud detection efforts. While some commenters generally expressed that we should ensure the process for requesting line separations is not cumbersome, none specifically addressed our proposed approach. We find that these requirements are consistent with the statutory requirements set forth in the SCA and properly balance the needs of survivors and covered providers' interest in preventing fraudulent line separations. 23. Affidavits Regarding an Individual in the Care of a Survivor. When a survivor is seeking a line separation for an individual in the care of a survivor, we require the survivor to submit an affidavit that is signed by the survivor and dated near the time of submission. We decline to adopt Verizon's suggestion, however, that we require such affidavits include the name of the individual being cared for, relationship of the survivor to the cared-for individual, or other information for fraud deterrence purposes. We conclude that requiring information about such individuals raises privacy concerns that are not outweighed by the potential fraud deterrence benefits, particularly given covered providers may not have this information documented in the shared mobile account in the first place. In addition, we agree with the New York City Mayor's Office to End Domestic and Gender-Based Violence (NYC ENDGBV) that there should not be a notarization requirement for affidavits, as such a requirement would be burdensome for survivors because they “may not have access to a form of identification to verify their identity to a notary and may not have the resources to find, travel to, or acquire a notary public.” 24. Documentation Demonstrating Survivor Status. Consistent with the SCA, we require survivors seeking a line separation to submit documentation that verifies that an individual who uses a line under the shared mobile service contract has committed or allegedly committed a covered act against the survivor or an individual in the survivor's care ( i.e., is an “abuser”). To meet the requirement for demonstrating survivor status, survivors must submit one or more of the eligibility documents prescribed by the SCA: (1) a copy of a signed affidavit from a licensed medical or mental health care provider, licensed military medical or mental health care provider, licensed social worker, victim services provider, licensed military victim services provider, or an employee of a court, acting within the scope of that person's employment; or (2) a copy of a police report, statements provided by police, including military or Tribal police, to magistrates or judges, charging documents, protective or restraining orders, military protective orders, or any other official record that documents the covered act. The documentation provided should clearly indicate a known name for the abuser and the survivor, as well as include some kind of affirmative statement that constitutes an indication that the abuser actually or allegedly committed an act that qualifies as a covered act against the survivor or an individual in the care of a survivor. No commenter opposed our establishment of such requirements. Consistent with the Commission's proposal, we also codify the proviso in the SCA stating that nothing in our rules implementing section 345(c) “shall affect any law or regulation of a State providing communications protections for survivors (or any similar category of individuals) that has less stringent requirements for providing evidence of a covered act,” which was unopposed in the record. 25. We interpret the phrase “any other official record that documents a covered act” to mean records from any governmental entity, including Tribal governments. We find that this is the best interpretation of this phrase because the documents listed preceding this phrase are records from government entities, and although they are specifically records from law enforcement entities, Congress did not limit the scope of the phrase by qualifying it with “any other official law enforcement record that documents a covered act.” We also find that this reading is most consistent with the goals of the SCA as it permits survivors to submit official records from other government entities not listed in the statute that might commonly assist survivors, such as child and family service agencies. No commenter urged us to interpret the phrase narrowly, and for the reasons discussed below, we decline to interpret this clause more broadly to allow survivors to submit self-certification of survivor status. We also decline to interpret the “other official record” phrase to include records of domestic violence services organizations, or medical or mental health records that describe treatment for injuries, without the need to obtain a signed affidavit from the provider, as the New York State Office for the Prevention of Domestic Violence requests as the first clause of the SCA's documentation provision specifically requires that such records be accompanied by a signed affidavit from the care provider and we find there is no basis for interpreting the “other official record” phrase to directly contradict that requirement. 26. Although we are sympathetic to concerns raised in the record that some survivors may have difficulty securing the documents specified by the SCA to demonstrate survivor status, or doing so in a timely manner, we find that there is no valid basis for interpreting the statute to allow self-certification of survivor status. Several commenters urge us to permit self-certification, but none explain how the SCA provides the Commission with the authority to do so, or how doing so is consistent with congressional intent. On the contrary, we find that doing so would contradict congressional intent. As the Commission explained in the Safe Connections NPRM, when Congress adopted the SCA, it was not unaware that self-certification could be an option for survivors to demonstrate survivor status, as the Commission had sought comment on allowing self-certification in its Notice of Inquiry. We expect that Congress also likely knew of the option for survivors to self-certify their status given that a similar New York law already permitted it as an option. Congress nevertheless excluded self-certification from its detailed list of permissible documentation. Presumably recognizing that the documentation requirements it set were more stringent than those that already existed in New York, Congress included a savings clause in the statute that specifically preserves states' ability to adopt less stringent certification requirements in state laws or regulations. Although EPIC et al. cites this provision as a reason why the Commission should conclude that the list of permitted documentation is non-exhaustive and that self-certification should be permitted, it is precisely because the SCA sets out a list of permitted documentation and preserves states' rights to set less stringent requirements in separate state laws that we conclude the Commission is restricted in its ability to expand the scope of permitted documentation to include self-certification. We likewise conclude that self-certification does not fit into the phrase permitting survivors to submit “any other official record that documents a covered act,” given our conclusion that Congress intended that clause to be limited to records created by government entities. We also find that the best reading of “official record” is a “record created by, received by, sanctioned by, or proceeding from an individual acting within their designated capacity,” which would not include self-certification. For many of the reasons discussed in this paragraph, we also conclude that the SCA does not permit us to allow survivors to submit any other forms of documentation of survivor status besides those already discussed. 27. Next, we do not require that such documentation be dated or that the date be within a certain time period before the survivor submits the line separation request. We agree with API-GBV that we should “provide flexibility to allow people to disclose victimization or to apply for protections at their own pace, given the risks that survivors face as they plan for their safety.” We also anticipate that many survivors may have sought assistance years before the effective date of the SCA and our implementing rules, and we do not want to deter those survivors from taking advantage of the new benefit that is available to them or require them to seek assistance again just for the purpose of having newer documentation created. We likewise do not require that the documentation show that the covered act occurred within a certain time period prior to the request. We are cognizant of how difficult it may be for survivors to seek assistance and expect there may be instances where a survivor reported a covered act years ago but has not done so again recently despite ongoing abuse. 28. Assessing the Authenticity of Documentation. The record reflects broad agreement from stakeholders that we should not require covered providers to assess the authenticity of the documentation that survivors submit, and therefore we decline to adopt such a requirement. We find this approach is appropriate given concerns that many covered providers may not have the expertise to accurately evaluate the authenticity of documentation and could mistakenly deny legitimate requests. We conclude, however, that the SCA does not prohibit covered providers from attempting to assess the authenticity of documentation and from denying line separation requests based on a reasonable belief the request is or may be fraudulent, and we therefore permit them to do so. Such authentication might include confirming the documentation is from an entity that actually exists, assessing whether the documentation has identifiers that demonstrate the documentation is actually a record of that entity, and comparing any identifying information in the documentation about the abuser and survivor with information in the covered provider's records to confirm that it matches. However, to protect survivor privacy, we prohibit covered providers from directly contacting entities that created any documentation to confirm its authenticity. To mediate concerns about the accuracy of covered providers' assessments, we emphasize that covered providers must first form a reasonable belief that a request is or may be fraudulent before denying the request, and urge covered providers to consider possible legitimate reasons for why submitted documentation may not pass a provider's standard authentication checks. For example, mismatched identifying information could result from a document's use of nicknames or other names that would not match providers' records. We find that allowing, but not requiring, a covered provider to attempt to authenticate submitted documentation balances the public interests of fraud prevention and ensuring survivors' ability to obtain legitimate line separations. Accordingly, we decline NYC ENDGBV's suggestion to altogether prohibit covered providers from attempting to authenticate documents submitted by survivors. 29. Assessing the Veracity of Evidence of Survivor Status. We prohibit covered providers from assessing the veracity of the evidence of survivor status contained within the submitted documents, or relying on third parties to do so. We expect that, in most cases, survivors will not be in a position to control what information other entities include in the documentation to ensure it clearly establishes survivor status. Thus, allowing covered providers to evaluate the truthfulness of the information provided and potentially use it as a basis for denying requests could limit legitimate line separations. We also make clear that the prohibition on assessing the veracity of survivor status evidence means that covered providers may not contact survivors to interrogate them about their experience, which “can be retraumatizing for survivors,” particularly since “providers are likely not trained in trauma-informed engagement.” The record affirms our belief that many covered providers may not have the expertise to accurately evaluate the veracity of the documentation survivors submit. We find that it would undermine the goals of the SCA if a covered provider denied a line separation based on an incorrect determination about the veracity of the evidence presented. We agree with Verizon and CTIA that the SCA's liability limitation clause provides protections for covered providers if they reasonably rely on the documentation survivors provide to demonstrate survivor status and approve line separation requests that turn out to be fraudulent. 30. Other Information. We do not, at this time, require a survivor who is not the primary account holder to submit other information, including passwords, about the account or the primary account holder, as the record does not show that such additional information is needed to address fraud and could be unnecessarily burdensome for survivors. No commenter advocated that we require such information. Rather, consistent with the concern raised in the Safe Connections NPRM, Verizon noted that “survivors may have little if any visibility into account information such as PINs, billing addresses, and primary numbers that an abuser may keep private.” We do, however, permit a covered provider to request the account number, primary phone number, full or partial address, and PIN or password associated with the account, as long as the covered provider makes clear to the survivor that such information is not required to process the line separation request and that the request will not be denied if the information is not provided or is inaccurate. We acknowledge Verizon's assertion that such information, if available, “could help a provider to process the [line separation request] more quickly in some cases, and to investigate and remedy transactions that later turn out to have been fraudulent or unauthorized.” 31. Assistance with Completing Line Separation Requests. To maximize survivors' ability to pursue line separation requests, we conclude that survivors may rely on assistance from other individuals, including the survivor's designated representative, to prepare and submit line separation requests. We agree with commenters that this approach maximizes survivor self-determination and agency, and that it could be particularly useful for individuals with disabilities or whose first language is not English. No commenter opposed this approach. While the SCA requires covered providers to effectuate line separations after receiving a completed line separation request from a survivor, it also permits survivors to indicate a designated representative for communications regarding line separation requests, which we find signifies Congress's expectation that survivors might rely on other individuals in relation to line separation requests. To ensure that covered providers have the means to identify the individuals who survivors select to assist with line separation requests, we require providers to request the name and relationship to the survivor for individuals who assist survivors and we require those assisting survivors to provide that information, along with a statement that the person assisted the survivor with the line separation request. Providers may use methods that are reasonably designed to confirm the identity of the “designated representative.” We expect that any added cost for requiring covered providers to request this information will be negligible. 32. Confidential Treatment and Secure Disposal of Personal Information. We adopt our proposal to require a covered provider, including any officer, director, and employee—as well as a covered provider's vendors, agents, or contractors that receive or process line separation requests with the survivor's consent, or as needed to effectuate the request—to treat the fact of the line separation request as well as any documentation or information a survivor submits as part of a line separation request as confidential, and securely dispose of the information not later than 90 days after receiving the information, consistent with the SCA. The record supports adoption of this requirement, including our proposed clarification that a “vendor,” as used in the SCA, includes a “contractor” who may receive a line separation request in its provision of services to a covered provider, on the basis that this interpretation reflects the business practices of covered providers and will mitigate privacy risks to survivors. We note that covered providers must abide by this requirement even if they are unable to process a line separation request. 33. We conclude that treating the line separation request itself, as well as documentation and information a survivor submits as part of a line separation request, as confidential means not disclosing or permitting access to such information unless subject to a valid court order, except: (1) to the individual survivor submitting the line separation request; (2) to anyone that the survivor specifically designates; (3) to those third parties necessary to effectuate the request ( i.e., vendors, contractors, and agents); and (4) to the extent necessary, to the Commission and the Universal Service Administrative Company (USAC) to process emergency communications support through the designated program or address complaints or investigations. We disagree with CTIA that the Commission should not afford protections to survivors (and alleged abusers) from the misuse of their data by law enforcement on the basis that doing so is outside the scope of the SCA and the Safe Connections NPRM. The SCA directs the Commission to adopt regulations concerning the line separations requirements, which includes the confidentiality requirements, and thus we find that addressing this issue is within the scope of the SCA. Given concerns expressed by EPIC et al., we find that requiring law enforcement to obtain a court order to access information about a line separation request is a necessary protection for survivors (and alleged abusers). We do not anticipate that this requirement will be burdensome for providers to implement given that they already have a duty to protect the confidentiality of proprietary information of customers, including a duty to prevent access to customer proprietary network information (CPNI) “[e]xcept as required by law or with the approval of the customer.” Additionally, requiring a court order prevents covered providers from being placed in a position of having to assess whether a law enforcement official may be misusing their official authority. 34. We limit providers from using, processing, or disclosing the line separation request—or any documentation or information submitted with line separation request—for purposes unrelated to implementing the request, providing services, or otherwise managing the survivor's account. We also conclude that the requirement to “treat” information submitted in connection with a line separation request as “confidential” prohibits covered providers from using, processing, or disclosing ( e.g., to joint-venture partners) such information for marketing purposes. 35. We confirm our tentative conclusion that to the extent that any information a survivor submits as part of a line separation request would be considered CPNI and therefore subject to disclosure to the customer or a designee, the SCA's confidentiality requirement nevertheless requires that such information (along with any information submitted by a survivor that would not be considered CPNI) be treated confidentially and disposed of securely. We conclude that this is the best reading of the SCA's language requiring confidential treatment “[n]otwithstanding Section 222(c)(2)” of the Communications Act. EPIC et al. agrees with this reading, and no commenter offered an alternative interpretation. Thus, although section 222(c)(2) normally requires telecommunications carriers to “disclose customer proprietary network information, upon affirmative written request by the customer, to any person designated by the customer,” when such CPNI is submitted by survivors as part of a line separation request, covered providers must follow the SCA's heightened requirements for confidentiality and secure disposal. 36. We decline to find that the identity of the abuser and the reason for the line separation ( i.e., the alleged abuse) should be treated as CPNI for the purpose of protecting the personal information of abusers, as requested by EPIC et al. Neither data element fits logically within the categories of information that constitute CPNI, and it need not for those data to benefit from the SCA's confidential and secure disposal protections, which protect the privacy of both survivors and alleged abusers. The confidentiality obligation itself, that is, requires that such information be protected. 37. To help ensure confidential treatment and secure disposal of information submitted with line separation requests, we also require covered providers to follow data security measures commensurate with the sensitivity of line separation requests, as well as the information and documentation submitted with line separation requests. Specifically, we require covered providers to implement policies and procedures governing confidential treatment and secure disposal of this information, train employees on those policies and procedures, and restrict access to databases storing such information to only those employees who need access to that information. We believe these baseline requirements will create the foundation for covered providers to treat line separation information confidentially and dispose of it securely. We conclude that these requirements will not be burdensome for most covered providers given that all telecommunications carriers and interconnected Voice over internet Protocol (VoIP) providers must already train employees to protect the confidentiality of proprietary information of, and relating to, other telecommunication carriers, equipment manufacturers, and customers and that we have specific rules governing the protection of CPNI, and we expect that most providers already have data security policies and procedures to limit access to certain information. In all cases, we anticipate that covered providers will only need to modify their practices and systems to include treatment of line separation information. 38. Understanding that covered providers may need flexibility to comply with the confidentiality and disposal requirements, we otherwise decline to prescribe specific measures that covered providers must use to treat information submitted with a line separation request as confidential and securely dispose of it. We conclude, however, that unauthorized disclosure of, or access to, information survivors submit as part of a line separation request will be considered evidence in an investigation by the Commission that a covered provider has not adopted sufficient measures to protect against such disclosure or access. This approach aligns with our expectations for carriers' treatment of CPNI. The SCA's confidentiality and disposal requirements demonstrate that Congress thought the privacy of information related to line separation requests is paramount, and we anticipate that our approach will incentivize covered providers to adopt best practices as they evolve over time to ensure the confidentiality and secure disposal of such information. Such best practices might include encryption, masking, data minimization ( i.e., only collecting data necessary for the intended purpose and deleting data when it is no longer necessary), access controls, secure password policies, traffic monitoring, and internal firewalls. Indeed, a covered provider may be able to overcome evidence related to a breach of survivor information if the provider is able to show that it used industry best practices at the time of the breach. We are also concerned that prescribing specific data security practices might result in the rules becoming obsolete over time. We make clear that the liability protections in the SCA do not shield covered providers, or their vendors, agents, and contractors, from enforcement actions that may result from their failure to adopt adequate practices to treat line separation information as confidential and securely dispose of it. Additionally, we emphasize that covered providers subject to section 222 have an independent responsibility to protect such confidential information and will therefore be subject to potential enforcement action for failures by their vendors, agents, and contractors to adopt sufficient confidentiality and secure disposal measures. 39. We also clarify the limited instances in which a covered provider may retain information about a line separation request beyond the 90-day disposal deadline established by the SCA. First, consistent with the SCA, we permit a covered provider to maintain a record that verifies that a survivor fulfilled the conditions of a line separation request for longer than 90 days, but prohibit providers to retain, as part of this record, the affidavit, documentation of survivor status, or other original records a survivor submits with the request, as that information is deemed confidential and subject to secure disposal within 90 days. Second, we permit a covered provider to retain any confidential record related to the line separation request, including an affidavit and documentation of survivor status, for longer than 90 days upon receipt of a legitimate law enforcement request. In both cases, we require a covered provider to treat the records it retains as confidential, and dispose of such records securely. To be clear, even though the record that verifies that a survivor fulfilled the conditions of a line separation request is not an original record submitted with a request, it must nonetheless be treated as a confidential record. We decline the Boulder Regional Emergency Telephone Service Authority's (BRETSA) suggestion that we require covered providers to deliver a 911 call placed by a survivor over the survivor's separated line with “some indication to the PSAP [public safety answering point] that the call is from service assigned to an individual escaping an abusive relationship.” We agree with commenters that such a requirement falls outside the scope of the SCA and our implementing rules. b. Required Options Covered Providers Must Offer to Survivors 40. We now adopt requirements regarding basic categories of information covered providers must make available to, or request from, survivors when granting a line separation request. These requirements are intended to streamline the line separation process for covered providers and to maximize the simplicity with which survivors can obtain line separations in a timely manner. First, we codify in our rules the SCA's requirement that a covered provider inform the survivor, through remote means, at the time the survivor submits a line separation request, that the provider may contact the survivor, or the survivor's designated representative, to confirm the line separation or inform the survivor if the provider is unable to complete the line separation. As explained in the Safe Connections NPRM, we find that this approach will allow survivors to make an informed choice regarding which contact information and manner of communication is best given their particular circumstances. No commenter opposed this approach. 41. Second, for line separation requests submitted by a survivor through remote means, we require covered providers to “allow the survivor to elect in the manner in which the covered provider may—(i) contact the survivor, or designated representative of the survivor, in response to the request, if necessary; or (ii) notify the survivor, or designated representative of the survivor, of the inability of the covered provider to complete the line separation,” which mirrors the SCA. We conclude that this requirement simply obligates a covered provider to allow a survivor to select, at the time the survivor submits a line separation request through remote means, the manner the provider must use to communicate with a survivor after the survivor submits the request. Among the communication options offered to the survivor, we require a covered provider to include at least one means of communication that is a “remote means.” We also require covered providers to allow survivors to indicate their preferred language for future communications from among those in which the covered provider currently advertises, and deliver any such future communications in the survivor's preferred language if it is one in which the provider currently advertises. Additionally, we require covered providers to ask survivors to provide the appropriate contact information with their requests. We decline Verizon's suggestion that we require a survivor to submit a telephone number and email address with its request for use in contacting the survivor. The SCA permits survivors to select the means that covered providers must use to communicate with them, which may or may not be both phone and email. To prevent covered providers from attempting to contact survivors using any other means, we only require survivors to provide contact information for the means they select, unless it is otherwise necessary to provide documentation of a completed line separation request for Lifeline purposes, as discussed below. We also prohibit providers from engaging in communications that are not directly related to the line separation request, such as marketing and advertising communications that are not related to assisting survivors with understanding and selecting service options. No commenter opposed adoption of these requirements. 42. Third, we require covered providers to allow a survivor submitting a line separation request to indicate their service choices when they are submitting a line separation request. Specifically, we require covered providers to allow a survivor to indicate the service plan a survivor chooses from among all commercially available plans the covered provider offers for which the survivor may be eligible, including any prepaid plans, as well as whether the survivor intends to retain possession (and therefore take financial responsibility) of any device associated with a separated line. API-GBV and the Competitive Carriers Association (CCA) both supported such a requirement, and no commenter opposed it. 43. Fourth, as mandated by the SCA, we require a covered provider to inform the survivor of the existence of the Lifeline program as a source of support for emergency communications for qualifying survivors, and to include a description of who might qualify for the program and how to participate. We require covered providers to provide this information to survivors as part of the line separation request mechanism as we anticipate that having this information may help survivors determine which service plan may suit them best. We require covered providers, at a minimum, to inform survivors that their participation in the Lifeline program and the Affordable Connectivity Program (ACP) based on their status as survivors will be limited to six months unless they can qualify to participate in Lifeline and/or ACP under the programs' general eligibility requirements. We decline to adopt standardized language regarding the content of this communication as we do not find it necessary at this time. We find that our approach provides sufficient guidance to covered providers regarding what information they must include in their communications. We also require covered providers to allow survivors to indicate whether they intend to apply for emergency communications support through the designated program, if available through the provider. 44. Finally, to the extent that a covered provider cannot operationally or technically effectuate certain types of line separations in all instances, we require a covered provider to identify—in a contemporaneous communication to the survivor—which types of line separations the provider cannot perform and state that it cannot perform those separations due to operational or technical limitations. 3. Requirement To Separate Lines Upon Request 45. We codify the SCA's requirement that, for a shared mobile service contract under which a survivor and abuser each use a line, a covered provider must, not later than two business days after receiving a completed line separation request from a survivor, (1) separate the line(s) of the survivor, and the line(s) of any individual in the care of the survivor, from the shared mobile service contract, or (2) separate the line(s) of the abuser from the shared mobile service contract. We conclude, as proposed, that because the SCA requires covered providers to implement line separation requests from survivors for shared mobile service contracts “under which the survivor and the abuser each use a line, ” neither the abuser nor the survivor must be the primary account holder for a line separation to be effectuated, regardless of whose line is separated from the account. We also find that a person who does not use a line on an account—but is a “survivor” under the statute because the person is someone who cares for another individual against whom a covered act has been committed or allegedly committed—would be able to request a line separation because the definition of “survivor” allows that person to stand in for the individuals in their care. 46. We acknowledge the seriousness of concerns raised in the records about dangers to survivors from spyware applications or software installed on a survivor's device that could remain after a line separation. We find, however, that regulation of such third-party applications and software is beyond the scope of the SCA. We further note providers' assertions that removal of such applications and software may not be within the control of the covered provider. However, with respect to carrier-branded apps and software on devices that may enable shared mobile plan account owners to track users' devices or provide access to customer information through online accounts, we expect covered providers to take all steps necessary to ensure that such apps and software do not enable an abuser to retain access to information about a survivor's line or device post-separation. 47. Below, we clarify covered providers' obligations under this requirement, and in doing so, we emphasize the importance of survivors' ability to obtain the line separations of their choosing in a timely manner while recognizing the practical challenges that covered providers may face in effectuating those separations. a. Identity Authentication 48. We first require that covered providers attempt to authenticate, using multiple authentication methods if necessary, that a survivor, or a person in the care of the survivor, requesting a line separation is a user of a specific line or lines, and permit covered providers to deny line separation requests when the survivor cannot be authenticated or the provider has a reasonable belief that the request is or may be fraudulent. Specifically, when the survivor is the primary account holder or a user designated to have account authority by the primary account holder (designated user), we require covered providers to attempt to authenticate survivors just as they would any other primary account holder or designated user. This means that requests coming from primary account holders and designated users must comply with any other Commission rules that apply to authentication of such individuals, including those related to access to CPNI and the Commission's rules adopted to address Subscriber Identity Module (SIM) swap and port-out fraud. When the survivor is not the primary account holder or a designated user, we require covered providers to attempt to authenticate their identity using methods that are reasonably designed to confirm the survivor, or a person in the care of the survivor, is actually a user of the specified line(s) on the account, and that such authentication shall also be sufficient for requesting a SIM change when made in connection with a line separation request. To the extent this requirement differs from other authentication requirements, see, e.g., 47 CFR 64.2010, the line separation authentication requirement we adopt in this document to implement 47 U.S.C. 345 serves as an exception to those other requirements. We agree with CTIA and CCA that providers may need flexibility to authenticate and therefore we decline to specify or otherwise limit the methods that covered providers can use to authenticate the identity of survivors who are not primary account holders. Although we acknowledge that some authentication methods may be less secure than others, the record demonstrates that certain methods, such as verification using phone calls or text messages delivered to a survivor's number or knowledge-based checks using call detail information, may be the only practical means in some instances to authenticate survivors who are not the primary account holder and about whom covered providers have no other information. 49. Our approach balances our twin goals of maximizing survivors' ability to obtain legitimate line separations and of preventing fraud. On this issue, industry commenters agreed that covered providers should be given flexibility on how to authenticate survivors and their ability to deny individuals who cannot be authenticated. Conversely, EPIC et al. asserted that the Commission should prioritize survivors' ability to access and use the line separations process over speculative concerns that the line separations process will be used for fraud. We find that the rule we adopt is sufficiently supported by the record and therefore we disagree with CTIA that it is necessary to find a consensus before establishing authentication requirements. We also find that the authentication requirement preserves account security by helping to prevent fraudulent account takeovers, protects privacy by preventing unauthorized access to account information, and ensures covered providers have the necessary account information to comply with our rules and the SCA, consistent with the issues the SCA requires the Commission to consider when adopting line separation rules. 50. We decline NCTA's request to permit covered providers to call or text lines of those in the care of the survivor that are the subject of the line separation request to confirm that the non-abuser individual “approves the separation request” or otherwise “confirm that the request is valid before approving it.” NCTA argues that covered providers “should be permitted to decline to process the line separation request if this verification is not completed ( e.g., because the abuser has taken the device associated with the line) and, instead, give the party requesting the separation the option of creating a new account with a new telephone number.” As an initial matter, the SCA contemplates that a survivor would be able to separate a line even when the abuser is in possession of the device associated with that line, and therefore we disagree that we should approve of covered providers denying separation requests for those lines in all instances. More significantly, we are concerned that allowing covered providers to attempt verification on other lines may alert abusers about the survivor seeking a line separation at an early stage in the process. This might occur, for example, if the abuser is near to or in possession of the devices associated with those lines, such as if the abuser is with children who are in the care of the survivor while the survivor is elsewhere seeking a separation that includes those children's lines. We therefore find that these potential threats to survivors and those in their care outweigh the potential fraud prevention benefits of NCTA's proposed verification process. b. Establishing “Secure Remote Means” for Line Separation Request Submissions 51. We codify the SCA's requirement that covered providers “offer a survivor the ability to submit a line separation request . . . through secure remote means that are easily navigable, provided that remote options are commercially available and technically feasible.” No commenter opposed this requirement, and we elaborate on the various aspects of this requirement below. 52. Secure Means. Consistent with the SCA's goals to protect the confidentiality of survivor information, we adopt requirements regarding the secure submission of line separation requests. First, we conclude that any means a covered provider offers survivors to submit a line separation request, including non-remote means, must be secure. Second, we find that, at a minimum, secure means are those that prevent unauthorized disclosure of, or access to, the fact of the line separation request or the information and documentation submitted with the line separation request during the submission process. Third, as with the Commission's CPNI rules and the rules we adopt above for confidential treatment and secure disposal of the records survivors submit to covered providers with a line separation request, we conclude that unauthorized disclosure of, or access to, the fact of the line separation request or the information and documentation submitted with a line separation request will be considered evidence in an investigation by the Commission that a covered provider did not provide a “secure” means for submitting the request. We otherwise decline to prescribe specific requirements for what constitutes “secure” with respect to the means of submitting line separation requests, but as with our rules governing treatment of line separation records, we expect our approach will incentivize covered providers to adopt best practices for security as they evolve over time. No commenter opposed our adoption of any such requirements. 53. Remote Means. Although the SCA does not define what constitutes “remote means,” we interpret that phrase in a manner that maximizes survivor flexibility for submitting line separation requests. First, we conclude that a “remote means” for submitting a line separation request is a mechanism that does not require the survivor to interact in person with an employee of the covered provider at a physical location. No commenter opposed this interpretation. We agree with API-GBV that this interpretation “is particularly important for survivors in remote areas, or in communities in which physically going to a single location might jeopardize a survivor's safety or confidentiality.” As such, requiring survivors to visit a brick and mortar store would not constitute remote means. Conversely, a form on a covered provider's website with the ability to input required information and attach necessary documents would constitute remote means. We also find that submissions via email, a form on a provider's mobile app, a chat feature on a provider's website, interactive voice response (IVR) phone calls, fax, and postal mail would constitute remote means. Additionally, we conclude that a live telephone interaction, text message communication, or video chat with a customer service representative would constitute remote means. We do not intend this list to be exhaustive as there may be other methods currently available or developed in the future that would not require a survivor to interact in person with an employee of a covered provider at a physical location. Furthermore, to maximize survivor choice, we conclude that covered providers can offer survivors means that are not considered remote as long as the provider does not require survivors to use those non-remote means or make it more difficult for survivors to access remote means than to access non-remote means. 54. Second, consistent with API-GBV and NYC ENDGBV's requests, we require covered providers to offer survivors more than one remote means of submitting a line separation request, and encourage them to offer several means. We are concerned that certain remote means may be so obsolete or so novel that they would be difficult for some survivors to access, and that if those means are the only ones a covered provider offers, they would deter survivors from pursuing a line separation. We also anticipate that offering alternative remote means will make line separations more accessible to survivors who may be using different technologies or have different levels of digital literacy. We conclude that when Congress directed covered providers to “offer a survivor the ability to submit a line separation request . . . through secure remote means, ” the word “means” in this context is ambiguous as to whether providers must offer one or more than one means. Given this ambiguity, and the lack of the singular article “a” before the phrase “secure means,” we interpret “means” as a plural noun. 55. Third, we conclude that the remote means a covered provider offers must allow survivors to submit any necessary documentation, but we permit providers to offer means that allow or require survivors to initiate a request using one method (such as an IVR phone call) and submit the documentation through another method (such as via email). This approach received support in the record and was otherwise unopposed. Fourth, we require covered providers to accept documentation in any common format, including, for example, pictures of documents or screenshots. We find that this approach will minimize difficulty for survivors seeking line separations. 56. Additionally, consistent with existing statutory and regulatory requirements, we make clear that a covered provider must offer alternative remote means that are accessible by individuals with different types of disabilities. The Accessibility Advocacy Organizations highlight the importance of such a requirement, explaining that such individuals are often at increased risk of domestic violence, and therefore that it is critical that they be able to access the protections afforded by the SCA. We decline, however, to require that covered providers offer direct video calling (DVC) as a means of submitting line separation requests, as the Accessibility Advocacy Organizations request. Although we appreciate that DVC may have benefits for survivors with disabilities who are seeking line separation requests, we decline at this time to impose any specific technology given the wide variety of providers and accessible technologies available. We instead strongly encourage covered providers to offer the “most accessible and effective services available,” such as DVC, whenever feasible. 57. Technically Feasible and Commercially Available Means. No commenter addressed whether secure remote means for submitting line separation requests are currently “technically feasible” and “commercially available,” and if not, how long it would take them to be. CTIA noted that the Safe Connections NPRM appropriately incorporated into the proposed rules the “commercial availability” and “technical feasibility” limitations that apply to certain requirements. We observe that the remote means we identify above are commonly used by commercial entities to interact with consumers and there are technological processes available to make each of those means secure. We also anticipate that many, if not all, of these mechanisms can be modified by covered providers to be used for line separation requests. Accordingly, we find that secure remote means for submitting line separation requests are currently both technically feasible and commercially available, and we anticipate that covered providers will be able to update their systems and procedures to implement use of more than one means before the rules go into effect. 58. Easily Navigable. We next address how the means to submit line separation requests must be “easily navigable.” To give covered providers flexibility and ensure they are positioned to request all the information they need to process line separations in a way that is most suitable for their systems, we decline to prescribe the specific format, process, or form covered providers must use for survivors to submit line separation requests, and instead allow covered providers to develop their own mechanisms. However, consistent with the record, to ensure consistency and predictability for survivors and the individuals and entities that assist them, reduce difficulty for survivors, and give covered providers clarity regarding their obligations, we establish several requirements for the mechanisms that covered providers develop to ensure they are easily navigable for survivors submitting line separation requests. Specifically, we require that the mechanisms: (1) use wording that is simple, clear, and concise; (2) present the information requests in a format that is easy to comprehend and use; (3) generally use the same wording and format on all platforms available for submitting a request; and (4) clearly identify the information and documentation that survivors must include with their requests, including clearly listing what survivors should have on hand when contacting the provider, and allow survivors to easily provide that information. We decline to create or mandate the use of a standardized form as requested by NYC ENDGBV as we find that allowing covered providers the flexibility to develop their own approaches while establishing requirements to ensure those mechanisms are easily navigable better balances providers' expertise with the need to streamline the process for survivors. Nevertheless, we encourage stakeholders to work together to develop such a standardized mechanism, to the extent one would be useful for covered providers. 59. We also require that the means through which a covered provider permits survivors to submit line separation requests must be available in all the languages in which the covered provider currently advertises its services as well as all formats ( e.g., large print, braille, etc.) in which the provider makes its service information available to persons with disabilities. We agree with EPIC et al. that a “lack of meaningful language access can further isolation created by an abuser,” and conclude that requiring language availability for the means of submitting requests will help alleviate that isolation. We decline, however, to adopt API-GBV's recommendation that covered providers offer “translated forms and instructions in a minimum of the 10 most commonly used languages in the provider's covered service area, as well as any other languages (if any) that the provider advertises its services in.” We find that such a requirement would be unreasonably burdensome on covered providers, particularly smaller providers, but we encourage all providers to know the predominant languages used in their respective communities and translate their materials into as many different languages as is feasible. At the same time, because we permit survivors to rely on assistance from designated representatives and others to pursue line separations, we anticipate that survivors who speak languages other than those in which a covered provider advertises its services can seek interpretation assistance if necessary. c. Processing of Line Separation Requests 60. Implementing Survivors' Election of Line Separation. Consistent with the statutory language, we interpret the line separation requirement as granting survivors the flexibility to pursue line separations in the manner that is best for their circumstances. We thus conclude, as proposed, that the SCA gives survivors discretion to request separation from the account of either the line(s) of the survivor (and the line(s) of any individuals in the survivor's care) or the line(s) of the abuser, regardless of whether the survivor is the primary account holder. We decline to prescribe the circumstances in which survivors may pursue each type of line separation, as CTIA and NCTA request. The industry trade groups specifically ask the Commission to dictate that when a survivor is a primary account holder, the abuser's line must be separated from the shared mobile service contract and that covered providers can process such line separations by canceling the abuser's line. NCTA makes a second request that the Commission stipulate that when a survivor is not a primary account holder, their lines (and the lines of individuals in the survivor's care) must be separated from the shared mobile service contract. In both circumstances, the industry groups assert that they are trying to avoid situations where they have to establish new accounts in the name of the abuser, which they say cannot be done without the abuser's knowledge and consent, thereby potentially compromising survivors' safety. NCTA also expresses concern that in instances when an abuser who is the primary account holder is separated from the shared mobile service contract and the survivor becomes the primary account holder, “the abuser likely would know details about the account such as the PIN or account number that could be used to compromise the survivor's service after the line separation.” However, NCTA does not explain why the covered provider would not allow the survivor, as the primary account holder, to change the PIN to prevent the abuser from accessing the account or use other measures to prevent the abuser from accessing the account. 61. As an initial matter, we find that the industry groups' requested approaches are contrary to the text of the SCA and disincentivizes covered providers from developing solutions that will allow survivors to obtain the line separations of their choosing, thereby limiting the SCA's benefits to survivors. For the same reasons, we decline to find that covered providers have the discretion to determine whether to separate the line of the abuser or the lines of the survivor (and those in the survivor's care). If Congress had intended to limit the types of line separations a survivor could request in a given circumstance, it could have easily said so. We are particularly unmoved by the suggestion that Congress intended that survivors who are primary account holders must separate the line of the abuser and that the abuser's line would then be canceled, as this outcome is no different than what primary account holder survivors can achieve now, and would therefore make the SCA's benefit in this regard superfluous. We do not presume to understand all the reasons why a survivor might choose to separate an abuser's line or their lines and the lines of those in their care, but Congress chose not to limit survivors' choices and neither do we. 62. Additionally, while we appreciate the practical challenges of effectuating line separations precisely as survivors request, we anticipate that covered providers will be able to address these situations without compromising survivor safety. For instance, covered providers may be able to create a temporary placeholder account and contact the abuser after the line separation has been completed (and the survivor has been notified) to request consent and the necessary information to establish a permanent account. Because temporarily suspended numbers are not permanently disconnected numbers, they are not “aging numbers” under the Commission's rules. Covered providers must ensure that telephone numbers assigned to a user of a shared mobile account and which are the subject of a line separation request remain available to be assigned to the user of that number ( i.e., a survivor, an individual in the care of a survivor, or an abuser). 63. Alternatively, covered providers could give survivors advance notice that the provider would need to contact the abuser prior to effectuating the line separation to request the abuser's consent and necessary account information, and survivors could then choose whether to proceed or select another line separation or account change option. Absent these or other solutions that providers may develop, a third option is that covered providers can rely on the operational and technical infeasibility exception established by the SCA and discussed further below. NCTA suggests that the Commission dictating survivors' line separation options is a better approach than allowing covered providers to deny line separations due to operational or technical infeasibility because “[s]urvivors who chose the incorrect option or required further guidance to complete the separation would be forced to engage in additional communications with the covered provider at a time when it may be difficult or even dangerous for a survivor to be involved in such exchanges.” While we acknowledge NCTA's concern, we believe that our requirement that a covered provider state in a contemporaneous communication which types of requests it cannot complete due to operational or technical infeasibility should address the concern. We nevertheless strongly encourage covered providers to strive to develop the means to allow survivors to separate lines as they see fit. 64. Verizon argues that “[i]f a survivor requests that an account owner abuser be removed from an account, in practice this may technically or operationally require the latter to consent to establishment of a new account, undermining Congress's objective of ensuring the line separation is not visible to the abuser,” and that “[t]he Safe Connections Act envisions that the wireless provider would create a new account for the survivor(s) in those circumstances.” We recognize that in situations where the survivor is not the account holder, it is more likely than not that the survivor will elect to establish a new account (rather than separate the line of the abuser from the existing account) because such a choice will delay notice to the abuser, and in some cases may be the only technical or operational solution available for the covered provider. But, contrary to Verizon's claim, the SCA does not contemplate that the line separation will be invisible to the abuser in all cases. Rather, the statute expressly contemplates that the primary account holder, who may be the abuser, may be notified about the line separation. Therefore we disagree with Verizon that the SCA envisions that covered providers would create a new account for survivors who might otherwise seek to separate an abuser who is the primary account holder just so that the separation is not visible to the abuser. 65. We also address the circumstances under which an individual who is “in the care of” a survivor may receive a line separation. As proposed, we adopt the same approach for determining who qualifies as “in the care of” the survivor for the purposes of line separation requests as we do for who may be considered someone “who cares for another individual” in the definition of “survivor.” Specifically, we conclude that phrase encompasses: (1) any individuals who are part of the same household, as defined in § 54.400 of the Commission's rules; (2) minor children of parents or guardians who are survivors even if the parents and children live at different addresses; (3) individuals who are cared for by a survivor by valid court order or power of attorney; (4) and a person over the age of 18 who is financially or physically dependent upon a parent, guardian, or caretaker ( e.g., a non-minor child financially dependent on his or her parents or guardians, but who no longer lives at the same address). We further find that, unlike the definition of “survivor,” for the purposes of line separation requests, an individual “in the care” of a survivor need not be someone against whom a covered act has been committed or allegedly committed. As we explained in the Safe Connections NPRM, the SCA defines “survivor” as including an individual at least 18 years old who “cares for another individual against whom a covered act has been committed or allegedly committed, ” but it requires covered providers to separate the lines of both the survivor and “ any individual in the care of the survivor,” upon request of the survivor. As such, we interpret these provisions to mean that covered providers must separate the lines, upon request, of any individual in the care of a survivor without regard to whether a covered act has been committed or allegedly committed against the individual in the care of the survivor. Some commenters expressed support for our interpretation and none objected. 66. Timeline for Processing Line Separation Requests. Recognizing the urgency with which survivors may be seeking line separation requests, we adopt a rule that clarifies the SCA's requirement that covered providers effectuate line separations not later than two business days after receiving a completed line separation request from a survivor. No commenters opposed this approach, although Verizon expressed opposition to a more stringent approach, such as requiring processing “48 hours after receipt.” Specifically, we require covered providers to process line separation requests as soon as feasible, but not later than close of business two business days after the day the provider receives a completed request. For example, requests received before midnight at the end of a Monday must be processed no later than close of business on Wednesday. Under our rule, covered providers must take all steps to effectuate line separation requests within the two business day timeframe, including reviewing the request to determine if it is complete and effectuating or rejecting the request. We conclude that our rule is consistent with the text and goals of the SCA. We recognize that in some instances, the two-business day standard we adopt will require the line separation to be completed within 48 hours, but that will not always be the case. For instance, when submissions are made on Fridays or during the weekend, a carrier will have longer than 48 hours to effectuate the line separation, though we would encourage them to effectuate it sooner whenever possible. 67. We define business days as Monday-Friday, 8 a.m. to 5 p.m., excluding provider holidays, which fulfills requests from industry commenters that we incorporate the same definition for business hours that make up a business day as is used in the Commission's porting rules. Notwithstanding the two-business day requirement, we clarify that our “rules do not undermine the Safe Connections Act's strong incentives for wireless providers to accommodate [line separation requests].” Therefore, “[i]f effectuating [a line separation request] is technically infeasible for a particular provider in two business days, but three days is feasible,” the covered provider can rely on the technical infeasibility exception to delay completion of the request rather than denying the request and requiring survivors to start the entire process again, as long as the provider notifies the survivor of the status of their request and the expected completion timeline within two business days of receiving the request. 68. We decline to require that covered providers process line separation requests in less than two business days in cases of emergency or extreme hardship for the survivor, as the National Domestic Violence Hotline requests. Although we appreciate that some survivors may experience increased urgency for their line separation requests, we agree with NCTA that Congress was likely aware of the hardship that survivors may be facing when it explicitly gave covered providers up to two business days to complete requests, and we otherwise anticipate that it would be difficult for covered providers to accurately determine which requests qualify as emergencies or extreme hardship. For the same reason, we decline requests to require that covered providers process line separation requests within two calendar days. However, we expect that requiring providers to complete all requests as soon as feasible will prevent undue delay in completion of requests. 69. Operational and Technical Infeasibility. We codify the SCA's provision that covered providers who cannot operationally or technically effectuate a line separation request are relieved of the obligation to effectuate line separation requests. Additionally, we conclude that any line separation a covered provider can complete within two business days under its existing capabilities, as those may change over time, does not qualify as operationally or technically infeasible. We conclude that because this provision specifies that covered providers are only relieved of the “requirement to effectuate a line separation request,” providers are generally obligated to offer survivors the ability to submit requests for line separations described in the statute, even if the provider may not be able to effectuate such separations in some instances. However, to avoid survivor confusion and minimize the need for communications between covered providers and survivors, if a covered provider cannot operationally or technically effectuate certain types of line separations in all instances, we require the covered provider to clearly notify the survivor in its Notice to Consumers and through whatever mechanisms survivors are permitted to use to request line separations, which types of line separations the provider cannot perform and state that it cannot perform those separations due to operational or technical limitations. 70. We require covered providers to take reasonable steps to be able to effectuate all types of line separations permitted by the statute, but decline to prescribe when a provider can rely on the operational or technical infeasibility exception. We find that the intent and spirit of the SCA's line separation requirement is that survivors be able to obtain the line separations of their choosing, and the record indicates that covered providers intend to and will be capable of effectuating most line separation requests. We therefore think it is appropriate that all covered providers be required to take reasonable steps to be able to effectuate all types of line separations. However, given the significant differences in covered providers' processes and systems, we conclude that we cannot categorically define which types of line separations qualify as operationally or technically infeasible and that the better course of action is to give providers flexibility to make such determinations. We nevertheless expect that all covered providers will be able to effectuate at least some types of line separations. 71. We also codify the SCA's requirement that a covered provider that cannot operationally or technically effectuate a line separation request must: (1) notify the survivor who submitted the request of that infeasibility, and (2) provide the survivor with information about alternatives to submitting a line separation request, including starting a new account for the survivor. The SCA uses the phrase “starting a new line of service” which is ambiguous. A new line, if made on the same shared account with the abuser, would not accomplish Congress's goal of ensuring survivors “establish[ ] independence from . . . abuser[s].” We thus understand this phrase to describe starting a new account for the survivor, which we believe accords with Congress's intent. We require covered providers to explain in the notification the nature of the operational or technical limitations that prevent the provider from completing the line separation as requested and any available alternative options that would allow the survivor to obtain a line separation. Consistent with the SCA, we require a covered provider to notify a survivor of any rejection of a line separation request as a result of operational or technical infeasibility at the time of the request, or for a request made using remote means, not later than two business days after the covered provider receives the request. Covered providers shall deliver these notifications in the manner of communication selected by the survivor at the time of the request and in the language selected by the survivor, if applicable. Verizon encourages the Commission to permit providers to give “short plain-English explanations” regarding the nature of a operational or technical limitation preventing the processing of a line separation. While we agree with Verizon that covered providers should not overwhelm survivors with technical explanations, we do require providers to give survivors as much information about the operational or technical limitation as will allow them to make informed decisions about what to do next, such as, e.g., revise their request, initiate a new request, or seek other options. 72. We conclude that covered providers must offer, allow survivors to elect, and effectuate any available alternative options that would allow survivors to obtain a line separation. This proposal was unopposed in the record. For example, if a covered provider is not able to separate an abuser's line from an account because the abuser is the primary account holder, but can separate the survivor's line from the account, the provider must offer that alternative. Likewise, if a covered provider is not capable of processing a line separation request in the middle of a billing cycle but can do so at the end of the billing cycle, the provider must offer that. This approach maximizes the benefits of the line separation requirement and helps prevent survivors from being forced into a less desirable alternative. We find that the approach we take here achieves the goals of the SCA without placing undue costs and burdens on covered providers. Verizon explains that “in some cases, a wireless provider may not be able to create a new account for a survivor without initially applying certain financial obligations as part of the account setup” and argues that “as long as those obligations are promptly waived by the system or the customer service employee after the new account is created, Congress's objective is met.” We agree; however, in such instances survivors must not be required to take additional steps for such financial obligations to be waived; the wavier must be automatic. 73. Finally, we also require covered providers to deliver a clear and concise notification to survivors, within two business days after receiving the request, if a line separation request is rejected for any other reason, and such notification must include the basis for the rejection and information about how the survivor can either correct any issues, submit a new line separation request, or select alternative options to obtain a line separation, if available. 74. Resubmissions. To ensure that survivors making legitimate line separation requests can receive timely relief, we conclude that any corrections, resubmissions, or selected alternatives for obtaining a line separation submitted by survivors following a denial should be treated as new requests and therefore must be processed by covered providers as soon as feasible, but not later than close of business two business days after the provider receives the request. We agree with EPIC et al. that “[t]ime may be of the essence when a survivor initiates the line separation request, and there is no reason a provider expected to respond within two days of the initial submission cannot respond within two days for subsequent submissions.” 75. Measures to Stop Abusers from Preventing Survivors from Obtaining Line Separations. We are concerned that some abusers may take preemptive steps to prevent survivors from obtaining line separations, particularly if an abuser becomes aware of a survivor's attempt to separate a line. We reiterate our conclusion in the Safe Connections NPRM that the SCA requires covered providers to complete non-fraudulent line separations as long as the request provides the information required or permitted by the statute and our implementing rules, subject to operational and technical feasibility. Accordingly, we implement rules to ensure survivors can obtain line separations notwithstanding abusers' efforts to prevent them from doing so. First, to stop an abuser or other user from removing the survivor's access to the line before the request is processed, we require covered providers to lock an account to prevent all SIM changes, number ports, and line cancellations (other than those requested as part of the line separation request pursuant to section 345 and our rules) as soon as feasible after receiving a completed line separation request from a survivor, and until a request is processed or denied. Second, given evidence in the record that abusers may seek to exert control over survivors and to ensure that account locks do not become an avenue for perpetuating abuse and other crimes, we require covered providers to effectuate line separations, and any number port and SIM change requests made by the survivor as part of the line separation request, regardless of whether an account lock is activated on the account. There is some evidence in the record that stalkerware apps and spyware can be used to further endanger survivors, and we think it is reasonable to conclude that some survivors may request a SIM change so they can keep their separated number, but use a new device, for safety reasons. Finally, in situations where any customer other than the survivor requests that the covered provider stop or reverse a line separation on the basis that the line separation request was fraudulent, covered providers must complete or maintain any valid line separation request and make a record of the customer's complaint in the customer's existing account and, if applicable, the customer's new account, in the event further evidence shows that the request was in fact fraudulent. We conclude that our approach here best balances the importance of account protection measures to prevent fraud with the goal of ensuring survivors can obtain legitimate line separations. 76. Notification to Primary Account Holders and Abusers. As contemplated by the SCA, we require a covered provider to inform a survivor who has submitted a line separation request, but who is not the primary account holder, of the date on which the covered provider intends to give any formal notification to the primary account holder. We also require covered providers to inform survivors of the date the covered provider will inform the abuser of a line separation, cancellation, or suspension of service, involving the abuser's line to the extent such notification is necessary. We require covered providers to give such notice to the survivor as soon as is feasible after receiving a completed line separation request. As API-GBV notes, by informing survivors of the date the abuser will learn of the line separation, covered providers will give survivors an opportunity to “do relevant and timely safety planning.” We prohibit a covered provider from notifying an abuser who is not the primary account holder when the lines of a survivor or an individual in the care of a survivor are separated from a shared mobile service contract. By limiting the scope of when covered providers may notify abusers of line separations, we acknowledge the concerns of multiple commenters who stress that “[o]ne of the most dangerous times for a victim is when they are attempting to leave an abusive situation and the abuser becomes aware of their intent.” We also prohibit a covered provider from notifying a primary account holder, or an abuser who is not a primary account holder, of a survivor's request for a SIM change when made in connection with a line separation request pursuant to section 345. We decline to require covered providers to further delay notification to a primary account holder or abuser whose line is being separated, as proposed by some commenters, though we permit and encourage covered providers to do so if operationally feasible. As some commenters have noted, a line separation request involving the separation of the abuser's line may require the abuser to become financially responsible for the line immediately following the separation, or to give consent to open a new account. In such situations, the covered provider may need to inform the abuser immediately upon or before separating the abuser's line, making a notification delay infeasible. In implementing processes to ensure that primary account holders and, when necessary, abusers, are not notified about line separations until the date that the covered provider has provided to the survivor, we emphasize that covered providers should be mindful of their existing internal systems and processes that may cause some or all account users to receive automatic notifications about account activity, which may serve as de facto notifications about the line separation request. d. Documentation of Completed Line Separation Request Submission 77. We require covered providers to provide a survivor with documentation that clearly identifies the survivor and shows that the survivor has submitted a legitimate line separation request under section 345(c)(1) and the Commission's rules upon completion of the providers' line separation request review process. The SCA limits access to “emergency communications support” in the designated program to those survivors that meet the requirements of section 345(c)(1) and that are experiencing financial hardship, regardless of their ability to otherwise participate in the designated program. As such, survivors will require documentation demonstrating their submission of a legitimate line separation request to enroll in Lifeline, as the designated program, and receive support. Although no commenter offered specific suggestions about the type of information that should be included in this documentation to process a request for Lifeline support, we rely on the Commission's substantial experience managing its affordability programs to determine an appropriate approach. Specifically, regarding survivor identity, we require that the documentation include the survivor's full name and confirmation that the covered provider authenticated the survivor as a user of the line(s) subject to the line separation request. We further require that covered providers give survivors this documentation even if the line separation request could not be processed due to operational or technical infeasibility, as long as the survivor submitted a completed request in accordance with the requirements of section 345(c)(1) and the Commission's rules. We observe that entry into the emergency communications program is not limited to only those survivors who successfully obtain a line separation, but rather to those who satisfy the requirements of section 345(c)(1) and are experiencing financial hardship. Finally, we require covered providers to provide this documentation to survivors in a manner that would allow the survivor to share that documentation with USAC when the survivor seeks Lifeline support pursuant to the SCA. Accordingly, covered providers must provide the documentation in a written format that can be easily saved and shared by a survivor, such as an electronic notice delivered over email, information in a survivor's new account that can be easily downloaded or captured via a screenshot, some method of text messaging that can be easily captured via screenshot, or regular mail delivered to an address designated in the request. Telephonic delivery of this notice is insufficient, as it will not allow the survivor to confirm that they complied with the requirements of the line separation process. Covered providers should deliver this documentation via the means selected by the survivor for communications regarding the line separation request, to the extent such means satisfy both requirements. We acknowledge, however, that depending on the methods a survivor chooses for communications with a covered provider regarding the line separation request, covered providers may not have contact information that would allow them to send certain written documentation, and we permit providers to request contact information only for the purpose of providing this documentation for Lifeline enrollment under the SCA. e. Employee Training 78. We conclude that all covered provider employees who may interact with survivors regarding a line separation request must be trained on how to assist them or on how to direct them to other employees who have received such training. Industry commenters stressed the need for flexibility regarding employee training requirements to account for differences in provider resources, customer bases, and systems. Moreover, NCTA noted that “avoiding prescriptive rules also would reduce the implementation burdens associated with the new requirements.” We believe that a flexible approach to training and customer service will best allow providers, particularly small providers, to account for differences in operational capabilities, resources, service models, and customer bases, and as such, we decline to adopt more prescriptive requirements regarding training of employees. Verizon noted that it “maintains a group of customer care employees specially trained to handle the sensitivities surrounding [line separation requests] from domestic violence survivors and to walk the survivors through the secure process of documenting the abuse, establishing a new account (or removing an alleged abuser from an existing account), selecting a service plan and, where requested, facilitating a number change or port out.” While we applaud Verizon's efforts and urge covered providers to consider a similar approach, we decline to mandate that every covered provider maintain specialized staff to address survivor line separation requests, as API-GBV suggests. The record reflects that not all providers, particularly small providers, may have the operational capabilities or resources to establish specialized units of staff. 4. Notice to Consumers 79. As proposed in the Safe Connections NPRM, we require covered providers to provide a “Notice to Consumers” with information about the options and process for a line separation request made readily available to all consumers through the provider's public-facing communication avenues. We specifically incorporate the SCA's requirement that covered providers “make information about the options and process” regarding line separations “readily available to consumers: (1) on the website and the mobile application of the provider; (2) in physical stores; and (3) in other forms of public-facing consumer communication” for this “Notice to Consumers.” The record reflects that the Notice to Consumers should be available in an “easy to find,” “prominent,” or “obvious” place on provider websites and applications, and as such, we require covered providers to place the Notice to Consumers, or a prominent link to it, on a support-related page of the website and mobile application of the provider, such as a customer service page. We agree with Verizon and NCTA that adopting a flexible, rather than a one-size-fits-all, requirement for the placement of the Notice to Consumers on provider websites and applications enables the wide variety of covered providers to display it in the way that is most suitable to their customers, and find that our approach here strikes the right balance between being minimally prescriptive and ensuring that there is some consistency between covered providers' practices. API-GBV suggests that we require providers to include links to other victim-related resources, such as the National Domestic Violence Hotline, or National Sexual Assault Hotline. We decline to do so as this is outside the scope of the requirements of the SCA. In physical stores, we permit covered providers to make the Notice to Consumers readily available via flyers, signage, or other handouts, and require covered providers, at a minimum, to ensure that any materials containing the Notice to Consumers in-store are clearly visible to consumers and accessible. We also require covered providers to provide the Notice to Consumers in-store in all languages in which the provider advertises within that particular store and on its website in all languages in wh [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A2023-25835. Public record. Not legal advice.