Undisclosed Tracking Identifier Consent Register

PROBLEM: On 7 March 2016 the FCC announced a settlement under which Verizon Wireless agreed to pay a $1.35 million fine to resolve an investigation into its use of Unique Identifier Headers — "supercookies" — inserted into customers' mobile web traffic from December 2012 and not disclosed until October 2014. The consent decree requires Verizon to obtain opt-in consent before sharing the identifier with third parties and to run a three-year compliance programme.

SOLUTION: An IBM Cloud Ideas compliance improvement that maintains an undisclosed-tracking-identifier consent register: every tracking identifier a carrier inserts, its disclosure, and each customer's opt-in or opt-out decision is recorded with its timestamp, so consent can be audited rather than assumed.

EVIDENCE BASIS: DOCUMENTED — FCC, 7 Mar 2016: Verizon Wireless $1.35M fine over "supercookie" Unique Identifier Headers (inserted Dec 2012, undisclosed until Oct 2014); opt-in consent required before sharing with third parties.