Cybersecurity Policy Report, PUC Eyes California LifeLine Changes to Protect User Privacy, (Oct 29, 2025)
The Public Utilities Commission is scheduled to vote at its Thursday meeting on an amended proposal to establish a process for Californians without a Social Security number (SSN) to enroll in the California LifeLine program.
The commission has amended the proposed order to address concerns about consumer privacy and the use of identity verification software, among other things. The revised decision allows for two enrollment pathways for eligible Californians without an SSN and eligible Californians who have an SSN.
The revised decision directs commission staff to work with the third-party administrator (TPA) to “create a direct enrollment pathway for individuals who are applying to California LifeLine without an SSN.”
“This approach offers better protection for applicants’ personally identifiable information by ensuring it is accessed and stored by an entity subject to the state’s stringent privacy requirements. It also minimizes the number of locations where this information may be stored and accessed. Staff should ensure the TPA has successfully integrated identity verification software into the intake process to validate applicants’ identity documents, and protect the California LifeLine program from approving an individual based on fraudulent documents,” the commission said in the revised draft order.
Service providers will not be permitted to enroll applicants who do not provide an SSN through their proprietary systems, the commission clarified in the revised decision. Instead, service providers will be required to refer subscribers to the California LifeLine program’s direct enrollment processes if they do not have an SSN.
“While tools other than SSNs may prevent duplicate applications, we nevertheless determine that providers may only enroll subscribers with SSNs through their proprietary systems. This determination is based on our concern that service providers are not subject to the same strict privacy restrictions as the Commission and the TPA,” the commission said.
The draft order clarifies that the California LifeLine TPA and service providers should not use California LifeLine consumers’ information for unauthorized purposes as specified by the commission or applicable state or federal law. “This requirement extends to any third-party that the California LifeLine TPA or service provider contracts with regarding California LifeLine.”
In addition, the commission said it was “reasonable to require that any identification verification vendor not retain California LifeLine consumers’ personal identification information submitted during the application process.” This data minimization process will “effectively and automatically opt out California LifeLine consumers from having their information sold or shared,” according to the draft order.
The draft decision directs commission staff to amend the contract with the TPA to include all changes to the application, enrollment, and implementation of identity software.
News: StateLegislation DataPrivacy