Topic:"Reasonableness Review" in M12600

open and transparent, best practice would be to identify that SINs were collected in the public facing Customer Privacy Policy . In my opinion, it was not best practice to omit this from the policy. - 68. In my opinion, aside from where ne...

AI summary The text argues that it was unreasonable for NSPI to collect SINs for customer authentication and identification, as it was unnecessary and not in line with best practices. It also criticizes NSPI's delayed and incomplete process to purge SINs from its systems, which left sensitive data vulnerable to exfiltration.

F. My Perspective ls Unique, Substantive, and Dtrectly Relevant The three issues I propose to address are not duplicative of the Consumer Advocate's mandate. They are: - (a) Unique: No other party in this proceeding is offering an intellig...

AI summary The author argues that their perspective on NSP's cybersecurity posture is unique, substantive, and directly relevant to the Board's mandate. They highlight that no other party is providing an intelligence-community-informed analysis of NSP's cybersecurity in light of NCTA threat warnings, and that their input addresses material questions about NSP's preparedness and response.

C. NSP's Argument lmproperlv Narrows the Scope of the Proceeding NSP's argument appears to rest on an improperly narrow construction of the proceeding's scope. If followed, it would limit the Board's inquiry to technical compliance with mi...

AI summary NSP's argument is criticized for narrowly defining the proceeding's scope, which would limit the Board's inquiry to technical compliance rather than a holistic assessment of NSP's cybersecurity posture. This approach is deemed inconsistent with the Board's mandate and the public interest in ensuring reasonable cybersecurity practices.

D. Assess Reasonableness, Not to Impose a Least-Cost Standard The relevant inquiry under Section 12(c)(iii) is whether the disbursements are reasonable and necessary, not whether they represent the least expensive means of participation. T...

AI summary The relevant inquiry under Section 12(c)(iii) is whether the disbursements are reasonable and necessary, not whether they represent the least expensive means of participation. The Cost Rules do not impose a least-cost standard.