MMTC, NPR Tell FCC To Drop Form 323 Requirement
November 20, 2009 at 4:27 AM (PT)
The MINORITY MEDIA AND TELECOMMUNICATIONS COUNCIL has joined the chorus of parties asking the FCC to reconsider the use of Social Security Numbers in the process of filing its new Form 323 ownership reports. The MMTC, in ex parte meetings memorialized in a letter to the FCC, cites concern over requiring individuals to submit their Social Security Numbers to the Commission for FCC Registration Numbers, calling the procedure "an unnecessary invasion of personal privacy."
The MMTC stressed that it supports expanded ownership information disclosures on an annual basis, but said, "These goals, however, do not necessitate the intrusion on personal privacy represented by a mandate to register Social Security numbers with the Commission. Such a requirement would impede compliance with the Commission’s enhanced ownership disclosure requirements."
NATIONAL PUBLIC RADIO, likewise, voiced the same concerns over the new form, meeting with Media Bureau Chief WILLIAM LAKE and his staff. In NPR's ex parte letter, it said, "The use of Social Security Numbers raises significant privacy concerns and administrative burdens. The parties further advised against extending this requirement to noncommercial stations, who currently file FCC Form 323-E. Such a requirement raises unique privacy issues and administrative burdens for noncommercial broadcasters. Finally, the parties reiterated their concerns about imposing new, onerous reporting requirements on NCE licensees when the FCC has not yet concluded what “ownership” means in the noncommercial context. The parties stressed that there are fundamental differences between equity ownership in the commercial sector and governance in the noncommercial sector."