GTT Communications - Team Telecom agreement
The Letter of Agreement conditions the GTT Companies’ proposed Section 214 authorization assignments and transfer of control on extensive national-security and law-enforcement safeguards reviewed by the Department of Justice, FBI, DoD, and DHS in connection with the FCC applications.
What it does The agreement replaces specified 2010, 2014, and 2017 Hibernia-related assurances for the GTT Companies and establishes continuing compliance obligations. GTT must maintain U.S.-based law-enforcement and security contacts; support lawful interception and lawful U.S. process; protect U.S. Records, domestic communications, and domestic communications infrastructure; restrict foreign access and disclosure; maintain cybersecurity and system-security plans; report security incidents within 72 hours; and submit principal-equipment, network, outsourcing, ownership, service-provider, and annual compliance information. The compliance-monitoring agencies may object to proposed personnel, equipment, vendors, storage locations, network operations centers, and outsourced or offshored providers.
Who it affects The commitments bind GTT Communications, GTT Americas, and GC Pivotal, including their personnel, foreign affiliates, contractors, managed network providers, and other service providers with relevant access. They also preserve CMA review, audit, site-visit, and information-access authority.
Why it matters The LOA illustrates Team Telecom mitigation accompanying FCC review of a telecommunications ownership and authorization transaction. It makes protection of U.S. customer and network data, supply-chain visibility, foreign-access controls, and cooperation with U.S. law enforcement enforceable conditions whose breach may support FCC action against relevant authorizations.
Key dates and numbers
- Executed July 12, 2022.
- Covers two FCC assignment/transfer applications, WC Docket No. 21-445, and TT 21-080 to -082.
- Requires, among other deadlines, 15-day LEPOC and security-officer nomination periods, 30-day equipment and provider notices, 60-day plan and network-map submissions, and annual reports beginning one year after FCC approval.
- Security incidents and specified breaches must generally be reported within 72 hours; CPNI incidents must be reported to the FBI and U.S. Secret Service within seven business days after reasonable determination.