201 E Route 142, Dahlgren, IL 62828
STATEMENT OF FCC CPNI RULE COMPLIANCE
This statement serves to explain how Futiva and its affiliated telecommunications carrier (collectively and individually “Company”), are complying with Federal Communications Commission (“FCC”) rules related to the privacy of customer network information. The type of information for which customer privacy is protected by the FCC’s rules is called “customer proprietary network information” (“CPNI”). The FCC’s rules restricting telecommunication company use of CPNI are contained at Part 64, Subpart U of the FCC’s rules (47 C.F.R. §§ 64.2001-2011).
All subsequent references to rule Sections refer to rules under Part 64, Subpart U unless indicated otherwise.
- Identification of CPNI
The Company has established procedures and trained employees having access to, or occasion to use customer data, to identify what customer information is CPNI consistent with the definition of CPNI under the Section 64.2003(g) and Section 222(h)(1) of the Communications Act of 1934 as amended (47 U.S.C. § 222(h)(1)).
- Identification of Services Affected by CPNI Rules
The Company has established procedures and trained employees to recognize the different types of telecommunications and non-telecommunications services that affect how the Company uses CPNI.
- Identification of Permissible Uses of CPNI without Customer Authorization
The Company has established procedures and trained employees having access to, or occasion to use CPNI, to identify uses of CPNI not requiring customer authorization under Section 64.2005.
- Identification of Uses of CPNI Requiring Customer Authorization
The Company has established procedures and trained employees having access to, or occasion to use CPNI, to identify uses of CPNI requiring customer authorization under Section 64.2007.
- Customer Notification and Authorization Process
The Company has established procedures, and trained employees responsible for obtaining customer authorization to use CPNI for marketing purposes, regarding the notice and approval requirements under Section 64.2008. The Company has complied with the notice requirements for Opt-Out. The Company does not provide CPNI to other parties and thus has not used the opt-in approval process.
- Record of Customer CPNI Approval/Non-Approval
The Company has developed and utilizes a system for maintaining readily accessible record of whether and how a customer has responded to Opt-Out approval as required by Section 64.2009(a).
- Procedures Protecting Against Disclosure of CPNI
The Company has implemented procedures for compliance with new Section 64.2010 including, but not limited to the following:
- Authentication of customers before disclosing CPNI on customer-initiated telephone contacts or business office visits;
- The Company provides customers with on-line access to customer account information for which the Company has initiated procedures to control access in compliance with Section 64.2010(c) comprising authentication through a password established in compliance with Section 64.2010(e);
- The Company has implemented password back-up authentication procedures in compliance with Section 64.2010(e); and
(d) The Company has implemented procedures to notify customers of account changes.
- Actions Taken Against Data Brokers and Responses to Customer Complaints
Pursuant to Section 64.2009, the Company makes the following explanation of any actions taken against data brokers and a summary of all customer complaints received in the past year concerning the unauthorized release of CPNI:
- Disciplinary Process
The Company has in place an express disciplinary process to address any unauthorized use of CPNI where the circumstances indicate authorization is required under Section 64.2009(b).
- Supervisory Review Process for Outbound Marketing
The Company has established a supervisory review process regarding its compliance with the rules for outbound marketing situations as required in Section 64.2009 (d). Prior to any outbound marketing effort, sales personnel must obtain supervisory approval of the proposed outbound marketing use. Any approval of CPNI use for outbound marketing efforts is limited to CPNI not requiring prior customer authorization or, where prior customer authorization is required, CPNI of customers having given the Company prior approval. The Company maintains records of its compliance for a minimum of one year.
- Procedures for Notifying Law Enforcement of CPNI Security Breaches
The Company has adopted procedures to comply with Section 64.2011 for notifying law enforcement of CPNI security breaches, together with related recordkeeping and deferred notification to customers.