MMTC Opposed to FCC's Collection Of Social Security Numbers

Is part of an expanded media ownership reporting form

The Minority Media & Telecommunications Council is opposed to the FCC's collection of Social Security numbers as part of an expanded media ownership reporting form (Form 323).

While MMTC strongly supports the enhanced ownership disclosures, it says that the goals of enhancing race and gender data collection should not require filing Social Security numbers with the Commission, which has serious security implications.

"Requiring a complete Social Security number adds no additional relevant information, places information in the Commission’s records that is not necessary to accomplish the intended purpose, and subjects the reporting person to significant potential dangers," said MMTC in a letter to the commission Wednesday. It pointed to security breaches, including a stolen NIH laptop that contained the Social Security numbers of over 1,000 people, including that of Joe Barton (R-Tex.), the current ranking member of the House Energy & Commerce Committee, which oversees the FCC.

A law firm representing broadcast groups has petitioned the commission to delay the Dec. 15, 2009 deadline for filing the forms, taking issue with the reporting requirements on procedural and privacy grounds.

The FCC has changed the form to require information from anyone with an attributable interest in a station rather than just the principal entity. The FCC requires those individuals to identify their social security number as a way to track and cross-check ownership to determine the full extent of ownership and influence.

Expanding the reporting requirements was part of an effort launched by then FCC Acting Chairman Michael Copps to get better and more complete owernship data as a way to tee up changes that increase the number of female and minority owners.

MMTC supports that effort, but says the commission could just as easily require the use of an address. Using a couple of familiar names atop CBS and NBC, the group argues that "''Leslie Moonves of 51 West 52d Street, New York' or 'Jeffrey Zucker of 30 Rockefeller Plaza, New York' provides enough information, if used consistently, to clearly identify the extent of the person’s involvement in the industry." Or, perhaps using only the last four digits of the SS number.

"MMTC urges the Commission to rethink its requirement for individual FRNs that require the submission of Social Security numbers. In that way the agency can get on with the much-needed task of restoring credible Form 323 data collection that is so vital to the FCC’s civil rights mandate," wrote MMTC President David Honig.