988 Geolocation Needs to Consider Privacy Implications, FCC Told

prevention hotline, according to docket 18-336 comments due Monday. The National Suicide Hotline Designation Act of 2020 requires a report to Congress on geolocation. Enabling such capabilities for 988 calls would be "a significant undertaking," and the FCC needs to ensure resources and attention aren't diverted from the primary task of 988 implementation, USTelecom said. It said a study would be needed of call flows, the existing and to-be-developed technology and a new funding mechanism. Providing automatic location information for 988 calls raises numerous technical, privacy and policy issues that need careful consideration, and the FCC should propose that stakeholders develop recommendations to address those issues that will need to be resolved if Lifeline will be expected to receive and manage location information of mobile wireless 988 callers, CTIA said. "Dispatchable location is the gold standard for public safety" when an emergency dispatch is needed, said APCO, noting it's technically feasible to get such information, as evidenced by the dispatchable information available for some mobile 911 calls. Backing provision of geolocation information to the Lifeline centers it administers, Vibrant Emotional Health said callers get better support when routed to a local community call center, but such routing is challenged because 80% of Lifeline calls come from mobile phones. That creates a challenge of matching a device's number to the caller's location, it said. Citing possible privacy concerns, the American Association of Suicidology said Lifeline should develop better standardized universal training because the current approach to active rescue and imminent risk is insufficient "and rel[ies] on subjective, emotional, and sometimes reactionary responses." Messaging should be clear on what crisis services are and how they differentiate from 911 or emergency services, and crisis centers outside the Lifeline network need to be involved in service provision, it said. The National Alliance on Mental Illness said the 988 system optimally should provide "'someone to call' (988 hotline), 'someone to respond' (mobile crisis teams), and 'somewhere to go' (crisis stabilization programs)," and geolocation is key to mobile crisis teams. It also said the FCC report should include the need for federal guidance and best practices on protecting callers' privacy "while simultaneously ensuring appropriate and timely responses to people in need of in-person assistance."