Comment by slabity
3 years ago
> Opt-in approval. The term “opt-in approval” refers to a method for obtaining customer consent to use, disclose, or permit access to the customer's CPNI. This approval method requires that the carrier obtain from the customer affirmative, express consent allowing the requested CPNI usage, disclosure, or access after the customer is provided appropriate notification of the carrier's request consistent with the requirements set forth in this subpart.
IANAL, but doesn't the "disclosure, or access after the customer is provided appropriate notification" make this entire "opt-in" definition completely legal?
I mean, it was easy for me to opt-out, but I really hate the fact that I had to do so in the first place.
No "affirmative, express consent allowing the requested CPNI usage, disclosure, or access" was obtained by the carrier after "the customer is provided appropriate notification of the carrier's request consistent with the requirements set forth in this subpart", so opt-in approval is not present. I don't see a way to parse this that equates notification to express consent.
You use more than one services from Google. You have to have a Google account before you sign up with Fi. Google is allowed to use opt-out.
§ 64.2005 Use of customer proprietary network information without customer approval.
(1) If a telecommunications carrier provides different categories of service, and a customer subscribes to more than one category of service offered by the carrier, the carrier is permitted to share CPNI among the carrier's affiliated entities that provide a service offering to the customer.
(1) I use a dedicated Google account for Fi, which does not subscribe to other services.
(2) Notwithstanding (1), this is not what the regulation contemplates a "category of service" to be. It is contemplating categories of telephony services, as indicated by "(i.e., local, interexchange, and CMRS)"