REMINDER - New CALEA Obligations Require Affected Entities to File SSI Plans and Monitoring Reports in the Near Future

As we explained in a previous update, FCC Details CALEA Obligations of Facilities-based Broadband Internet Access Providers and Interconnected VoIP Service Providers (May 18, 2006), interconnected VoIP providers and facilities-based broadband Internet access service providers must be in compliance with CALEA, the federal statute requiring communications providers to cooperate with law enforcement surveillance requests, by May 14, 2007.

However, prior to that deadline there are a number of interim requirements under the FCC’s new CALEA regime. First, affected entities must file with the FCC a systems security and integrity (“SSI”) plan that details the policies and procedures used to ensure compliance with the CALEA regulations promulgated by the FCC. This document establishes procedures to ensure proper supervision and control of employees responding to law enforcement surveillance requests; and to maintain secure and accurate records of each interception of communications or access to call-identifying information. Second, all affected entities must file interim monitoring reports with the FCC. These reports are intended to demonstrate that all affected entities will be in compliance by May, 2007.

Last week, the FCC announced the following deadlines for these filings:

• CALEA monitoring reports must be filed no later than February 12, 2007; and
• CALEA SSI plans must be filed no later than March 12, 2007.

If you would like additional information or assistance in developing, reviewing or filing your systems security and integrity plans, please contact us.