cpni manual.docx

8/20/2019 CPNI Manual.docx

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CPNI POLICY ACKNOWLEDGEMENT

I hereby state and acknowledge that I have received a copy of the CUSTOMER PROPRIETR!

"ET#OR$ I"%ORMTIO" COMP&I"CE M"U& '(g(st )**+ ,ersion-. that I a/responsible for reviewing and (nderstanding this Man(al. and that I (nderstand that any violationof the Co/pany0s CP"I proced(res /ay res(lt in disciplinary action (p to and incl(dingdis/issal1

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#IT"ESSE34

CP"I COMP&I"CE O%%ICER

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CUSTOMER PROPRIETARY NETWORK INFORMATION

MANUAL

AUGUST, 2007 VERSION

This Man(al governs all (se of c(sto/er proprietary network infor/ation 'CP"I- by allCo/pany e/ployees. agents. independent contractors and 5oint vent(re partners1

It is the oi!i"# $o#i!% o the Co&$"'% th"t "## "!!ess, (se, )is!#os(*e o* )ist*i+(tio' o

CPNI +e i' "!!o*)"'!e ith the !(sto&e* $*i-"!% s"e.("*)s set o*th i' the

Co&&('i!"tio's A!t /7 U1S1C1 2223 "') the Fe)e*"# Co&&('i!"tio's Co&&issio'

/FCC3 R(#es /7 C1F1R1 412005 th*o(.h 4120553, "') th"t "## Co&$"'% e&$#o%ees,


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".e'ts, i')e$e')e't !o't*"!to*s "') 6oi't -e't(*e $"*t'e*s ho h"')#e the Co&$"'%s

CPNI "*e ""*e o these !(sto&e* $*i-"!% s"e.("*)s "') !o&$#% (##% ith the&1

It is the responsibility of all Co/pany e/ployees. agents. independent contractors and 5ointvent(re partners to read and review this Man(al. and to seek clarification fro/ the Co/pany0s

CP"I Co/pliance Officer regarding any CP"I6related 7(estions. before accessing. (sing.disclosing or distrib(ting CP"I in any /anner and for any p(rpose1 It is f(rther theresponsibility of every Co/pany e/ployee. agent. independent contractor and 5oint vent(re partner to co/ply f(lly with all federal CP"I re7(ire/ents. and to seek clarification fro/ theCo/pany0s CP"I Co/pliance Officer any ti/e that an access. (se. disclos(re or distrib(tion of CP"I appears to be 7(estionable1

"OTE4 So/e co/panies /ay retain individ(als or entities as 8agents.9 rather than as8independent contractors19 In co//on lang(age as well as legal analyses. there is not always aclear dividing line between 8agents9 and 8independent contractors19 Under basic co//erciallaw. an 8agent9 is a non6e/ployee a(thori:ed to act on the behalf of the Co/pany and bo(nd by

a fid(ciary d(ty to act in the Co/pany0s best interests. whereas an 8independent contractor9 is anentity that co/pletes a task (nder contract for the Co/pany b(t is generally responsible to theCo/pany pri/arily for the res(lts of its work while re/aining generally free to choose its own/eans and /ethods of perfor/ing and co/pleting the work1 The two ter/s are often (sedinterchangeably in b(siness disc(ssions and doc(/ents. and appear to overlap so/ewhat even in/ore precise legal ter/inology1

The 8agent;independent contractor9 distinction has significance for CP"I co/pliance p(rposes1%or e


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The %CC0s r(les. on the other hand. place stringent restrictions (pon CP"I access. (se.disclos(re and distrib(tion to 8independent contractors9 for /arketing p(rposes1 ccordingly. toens(re co/pliance with the %CC0s /arketing restrictions. the Co/pany will designate and treatany third party to which it f(rnishes CP"I for /arketing and /arketing6related (ses as an8independent contractor9 for p(rposes of co/pliance with the CP"I /arketing r(les (nless and

(ntil it seeks and obtains a clear legal opinion fro/ %CC co(nsel that it /ay do otherwise (nder specific circ(/stances1

VoIP Se*-i!es8 The %CC0s CP"I R(les '>+ C1%1R1 ??@>1)**A thro(gh @>1)*AA- apply to all providers of teleco//(nications services and to all providers of interconnected ,oice over Internet Protocol '8,oIP9- services1

I1 C(sto&e* P*o$*iet"*% Neto*9 I'o*&"tio' /:CPNI;3

CPNI is defined in Section )))'f- of the Co//(nications ct as '- infor/ation that relates

to the 7(antity. technical config(ration. type. destination. and a/o(nt of (se of ateleco//(nications service s(bscribed to by any c(sto/er of a wireline or wirelessteleco//(nications carrier. and that is /ade available to the carrier by the c(sto/er solely by virt(e of the carrier6c(sto/er relationshipB and '- infor/ation contained in the bills pertaining to telephone e


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I1 C(sto&e* P*o$*iet"*% Neto*9 I'o*&"tio' /!o't)3

Infor/ation regarding !(sto&e* $*ee**e) !"**ie* /:PC;3 *ee


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II1 Use "') Dis!#os(*e o CPNI Is Rest*i!te)

GENERAL RULE8 =e!"(se CPNI i'!#()es i'o*&"tio' th"t is $e*so'"# "')i')i-i)("##% i)e'tii"+#e, $*i-"!% !o'!e*'s h"-e #e) Co'.*ess "') the FCC to i&$ose

*est*i!tio's ($o' its (se "') )is!#os(*e, "') ($o' the $*o-isio' o "!!ess to it +%

i')i-i)("#s o* e'tities i'si)e "') o(tsi)e the Co&$"'%1

In the wake of the i/proper provision or sale of CP"I to certain Internet sites. the %CC has/ade it clear that it will i/pose swift and potentially severe sanctions (pon co/panies thatviolate its CP"I re7(ire/ents1 The %CC has stated that it e


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IV1 T*"i'i'. "') Co't*"!t A**"'.e&e'ts Re."*)i'. CPNI

A1 E&$#o%ee "') A.e't T*"i'i'.

,ario(s Co/pany e/ployees and agents /ay access. (se. disclose or distrib(te c(sto/er

records containing CP"I1 These e/ployees and agents /ay incl(de4 'a- officers and/anagersB 'b- c(sto/er service representativesB 'c- disp(te resol(tion personnelB 'd-acco(ntants and bookkeepersB 'e- billing and collection personnelB 'f- sales and /arketingrepresentativesB 'g- acco(nt representativesB and 'h- technicians and installers1

efore accessing. (sing. disclosing or distrib(ting any c(sto/er0s CP"I. a Co/panye/ployee or agent /(st co/plete the following CP"I Training Progra/4

A1 The e/ployee or agent /(st receive. read and review this Man(al. incl(ding theattached copies of 'a- Section ))) of the Co//(nications ct 'ttach/ent A-B 'b- the%CC0s CP"I R(les 'ttach/ent )-B 'c- the Co/pany0s CP"I notices 'ttach/ents .

> and F-B 'd- the Co/pany0s C(sto/er CP"I Re7(est %or/ 'ttach/ent @-B and 'e-the te/plate for the Co/pany0s ann(al CP"I Co/pliance Certificate 'ttach/ent +-1

NOTE8 E"!h Co&$"'% e&$#o%ee o* ".e't &(st si.' the CPNI POLICY

ACKNOWLEDGEMENT "tt"!he) to this M"'("# "t the ti&e th"t he o* she

*e!ei-es the M"'("#1

)1 The e/ployee or agent /(st attend a gro(p training session 'or. where ti/ing and;or other circ(/stances render a gro(p training session i/practicable. a private /eeting-with the Co/pany0s CP"I Co/pliance Officer d(ring which this Man(al will bereviewed and disc(ssed1

1 E/ployees and agents /(st attend ann(al Co/pany reviews of CP"I policies.re7(ire/ents and iss(es1

=1 Co't*"!t A**"'.e&e'ts o* A.e'ts, I')e$e')e't Co't*"!to*s "') >oi't Ve't(*e

P"*t'e*s

efore an independent contractor or 5oint vent(re partner /ay receive or be allowed toaccess or (se CP"I for the p(rpose of /arketing co//(nications6related or other services toa partic(lar c(sto/er. the Co/pany /(st have obtained a signed 8Opt6In CP"I "otice9'ttach/ent F- fro/ that c(sto/er1


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IV1 T*"i'i'. "') Co't*"!t A**"'.e&e'ts Re."*)i'. CPNI /!o't)3

=1 Co't*"!t A**"'.e&e'ts o* A.e'ts, I')e$e')e't Co't*"!to*s "') >oi't Ve't(*e

P"*t'e*s /!o't)3

efore an agent. independent contractor or 5oint vent(re partner /ay receive or be allowed toaccess or (se the Co/pany0s CP"I. the agent0s. independent contractor0s or 5oint vent(re partner0s agree/ent with the Co/pany /(st contain provisions 'or the Co/pany and theagent. independent contractor or 5oint vent(re partner /(st enter into an additionalconfidentiality agree/ent which provides- that4 'a- the agent. independent contractor or 5ointvent(re partner /ay (se the CP"I only for the p(rpose for which the CP"I has been providedB 'b- the agent. independent contractor or 5oint vent(re partner /ay not disclose or distrib(te the CP"I to. or allow access to the CP"I by. any other party '(nless the agent.independent contractor or 5oint vent(re partner is e


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VI1 Pe*&issi+#e Uses o CPNI O+t"i'e) *o& C(sto&e*s

Co/pany e/ployees and agents are strictly prohibited fro/ accessing or (sing CP"I. andfro/ disclosing or distrib(ting CP"I to individ(als or entities inside or o(tside the Co/pany.e@!e$t as follows4

A1 Re(ests o* CPNI *o& L" E'o*!e&e't

A1 The Co/pany will provide CP"I 'incl(ding call detail infor/ation- to a lawenforce/ent agency in accordance with applicable legal re7(ire/ents1 Denerally. s(chlegal re7(ire/ents entail an appropriate warrant or s(bpoena that specifies the partic(lar CP"I to be f(rnished1

)1 Co&$"'% e&$#o%ees, ".e'ts, i')e$e')e't !o't*"!to*s "') 6oi't -e't(*e $"*t'e*s&(st )i*e!t "## #" e'o*!e&e't *e(ests o* CPNI /hethe* o* 'ot "!!o&$"'ie)

+% " "**"'t o* s(+$oe'"3 to the CPNI Co&$#i"'!e Oi!e*, ho i## +e

*es$o'si+#e o* h"')#i'. s(!h *e(ests "') o* !o's(#ti'. ith !o('se#/$"*ti!(#"*#% i' "'% i'st"'!es he*e #" e'o*!e&e't !#"i&s th"t " "**"'t o*

s(+$oe'" is 'ot *e(i*e)31

=1 Re(ests o* CPNI *o& C(sto&e*s o* P(*$o*te) C(sto&e*s

A1 Te#e$ho'e Re(ests o* C"## Det"i# I'o*&"tio'1 #hen a c(sto/er or a personclai/ing to be a c(sto/er calls the Co/pany to re7(est call detail infor/ationregarding the c(sto/er over the telephone. the Co/pany will provide the re7(ested calldetail infor/ation o'#% (nder the following three alternative circ(/stances4

'i- the Co/pany /ay provide the re7(ested infor/ation over the telephone d(ringthe c(sto/er6initialed call I%B 'a- the caller provides a pre6established passwordthat /eets the re7(ire/ents in paragraphs A1a thro(gh A1g1 belowB or 'b- the caller correctly answers the pre6established 8shared secret9 7(estions co/prising theCo/pany0s back6(p c(sto/er a(thentication /ethod for that c(sto/er 'if he or she loses or forgets his or her password-

'ii- the Co/pany /ay. at the c(sto/er0s re7(est. send the re7(ested call detailinfor/ation to the c(sto/er0s postal or electronic 8address of record9 'whichaddress /(st have been associated with the c(sto/er0s acco(nt in the Co/pany0s billing and service records for at least the previo(s * days-B or

'iii- the Co/pany /ay ter/inate the c(sto/er6initiated call. initiate a call to thec(sto/er0s 8telephone n(/ber of record9 'which /(st be the telephone n(/ber associated with the (nderlying service. and /ay not be so/e other telephonen(/ber s(pplied as part of the contact infor/ation for the c(sto/er- and disclosethe re7(ested call detail infor/ation to the c(sto/er d(ring the Co/pany6initiated call1


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VI1 Pe*&issi+#e Uses o CPNI O+t"i'e) *o& C(sto&e*s /!o't)3

=1 Re(ests o* CPNI *o& C(sto&e*s o* P(*$o*te) C(sto&e*s /!o't)3

a1 Passwords can be designed in a /anner that is privately significant and /e/orable

to the c(sto/er 'e.g.. 8piratesAG+A.9 8AH@ala/o.9 8beatles>9-1 =owever. passwords/ay "OT be based (pon readily obtainable biographical infor/ation 'e.g.. thec(sto/er0s na/e. /other0s /aiden na/e. social sec(rity n(/ber or date of birth- or acco(nt infor/ation 'e.g.. the c(sto/er0s telephone n(/ber. address. acco(nt n(/ber.or a/o(nt of last bill-1

b1 The Co/pany will establish a password 'and a back6(p c(sto/er a(thentication/ethod if the c(sto/er loses or forgets his or her password- for each new c(sto/er atthe ti/e that the c(sto/er initiates service1

c1 The Co/pany will establish a new or replace/ent password 'and a back6(p

c(sto/er a(thentication /ethod if the c(sto/er loses or forgets his or her password-for e


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e1 eca(se prete


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)1 Te#e$ho'e Re(ests o* CPNI Th"t Is Not C"## Det"i# I'o*&"tio'1 #hen a

c(sto/er or a person clai/ing to be a c(sto/er calls the Co/pany to re7(est over thetelephone CP"I regarding the c(sto/er that is not call detail infor/ation 'e1g1.infor/ation abo(t the teleco//(nications and infor/ation services p(rchased by thec(sto/er-. the Co/pany e/ployee handling the call /(st establish that the personcalling is act(ally the na/ed c(sto/er. b(t is not presently re7(ired by %CC R(les tohave the caller f(rnish a pre6established password1 =owever. given the potentialsanctions i/posed (pon (na(thori:ed disclos(re of CP"I and the lack of %CCg(idance regarding acceptable alternative /ethods of c(sto/er a(thentication.Co/pany e/ployees will a(thenticate all telephone re7(ests for CP"I in the sa/e/anner whether or not the CP"I consists of call detail infor/ation1 That is. Co/panye/ployees /(st4 'a- be f(rnished the c(sto/er0s pre6established password 'or correct

answers to the pre6established back6(p 8shared secret9 co/binations-B 'b- send there7(ested infor/ation to the c(sto/er0s postal or electronic 8address of record9 'seedefinition above-B9 or 'c- call the c(sto/er back at the c(sto/er0s 8telephone n(/ber of record9 'see definition above- with the re7(ested infor/ation1

1 C(sto&e* I'?=o(') M"*9eti'. C"##s1 #hen an e


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>1 W*itte' Re(ests o* CPNI1 Upon receiving an appropriate written re7(est fro/ a

c(sto/er. the Co/pany will provide to the c(sto/er or to any person designated by thec(sto/er a written doc(/ent containing specifically re7(ested portions of thec(sto/er0s CP"I1 ny and all s(ch c(sto/er re7(ests4 'A- /(st be /ade in writingB')- /(st incl(de the c(sto/er0s correct billing na/e and address and telephonen(/berB '- /(st specify e


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F1 I'?Pe*so' Re(est "t =(si'ess Oi!e o* Ret"i# Lo!"tio' 1 8c(sto/er of record9

'i1e1. a c(sto/er whose na/e is on the acco(nt- /ay review and;or obtain copies of hisor her CP"I at any Co/pany b(siness office or retail sales location where s(ch CP"Iis available by co/ing in6person to the facility and presenting a driver0s license. passport or other govern/ent6iss(ed identification that verifies his or her identity. andthat lists an address that is the sa/e as the c(sto/er0s 8address of record19

@1 =(si'ess C(sto&e* E@!e$tio'1 The Co/pany /ay contract with certain /(lti6line b(siness c(sto/ers for different proced(res to handle the b(siness c(sto/er0s re7(estsfor CP"I1 S(ch alternative proced(res /(st be reviewed by the CP"I Co/plianceOfficer and co(nsel before they are i/ple/ented1 t /ini/(/. the alternative proced(res re7(ire the Co/pany to assign an e/ployee as the dedicated acco(nt

representative with pri/ary responsibility for handling all CP"I re7(ests fro/ the b(siness c(sto/er1 +1 A)(#t Chi#)*e' o E#)e*#% C(sto&e*s1 The Co/pany is aware that ad(lt children 'or

other relatives- of elderly c(sto/ers /ay have legiti/ate needs to /ake servicechanges or to raise and resolve billing 7(estions on behalf of their parents1 t the sa/eti/e. the Co/pany has concerns that a prete


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C1 Re(ests o* CPNI *o& Co&$eti'. C"**ie*s "') Othe* Thi*) P"*ties /!o't)3

)1 c(sto/er /ay re7(est in writing that his or her CP"I be delivered to a co/peting

carrier or other third party1 If the written re7(est is presented by the c(sto/er in personat the Co/pany0s b(siness office. the Co/pany will f(lfill it if the c(sto/er presents adriver0s license. passport or other govern/ent6iss(ed identification that verifies his or her identity. and that lists an address that is the sa/e as the c(sto/er0s 8address of record9 'see definition above-1 If the written re7(est is received via U1S1 /ail or other recogni:ed delivery service. the Co/pany will call the c(sto/er0s 8telephone n(/ber of record9 'see definition above- and;or send a notification of the c(sto/er0s re7(est tothe c(sto/er0s 8address of record9 'see definition above- to verify the acc(racy of thisre7(est1 s noted in Section ,I11> above. this is a sensitive area that /ay place theCo/pany in the /iddle of potentially conflicting %CC and stat(tory policies regardingCP"I protection and teleco//(nications co/petition1 ny 7(estions or concerns

regarding the validity of a written re7(est by a 8c(sto/er9 for delivery of CP"I to aco/peting carrier or other third party /(st be bro(ght i//ediately to the attention of the CP"I Co/pliance Officer1 It is the preference of the Co/pany that in s(chinstances. the re7(ested CP"I be provided directly to the c(sto/er. who is then free todeliver it to the desired third party1 =owever. if the c(sto/er cannot be pers(aded tofollow this co(rse. the proced(res in this paragraph sho(ld be followed1

D1 Use o CPNI o* M"*9eti'. P(*$oses

A1 M"*9eti'. A!ti-ities Not I'-o#-i'. CPNI1 Marketing activities that do not (seCP"I are not restricted in any /anner by the federal CP"I re7(ire/ents1 TheCo/pany0s e/ployees. independent contractors and 5oint vent(re partners /ay senddirect /ail advertise/ents to ho(seholds and b(sinesses in vario(s geographic areas'incl(ding co//(nities. neighborhoods and :ip codes- as long as they do not (seCP"I to design the direct /ail ca/paign or to target partic(lar recipients1 Suchdirect mail advertisements may be included as inserts in the monthly bills sent to the

Company’s customers, as long as CPNI is not used to target particular customers or

to provide particular bill inserts to particular customers. The Co/pany0se/ployees. independent contractors and 5oint vent(re partners /ay also engage intele/arketing 's(b5ect to do6not6call list restrictions- to ho(seholds and b(sinesses in partic(lar co//(nities or e


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D1 Use o CPNI o* M"*9eti'. P(*$oses /!o't)3

)1 :Tot"# Se*-i!e A$$*o"!h; M"*9eti'. A!ti-ities1 The Co/pany0s e/ployees 'b(t

not its independent contractors or 5oint vent(re partners- /ay access and (se CP"I.witho(t c(sto/er approval. to provide or /arket to a c(sto/er the sa/e 8category9or 8package9 of services to which the c(sto/er presently s(bscribes fro/ theCo/pany1 The %CC refers to this as the 8total service approach19 In other words. tothe e


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e1 SPECI& %CC &EC;IJC RU&E4 If the Co/pany provides local e


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SECTION D1

>1 Use o CPNI o* Co&$"'%?I'iti"te) /O(t?=o(')3 M"*9eti'. P(*$oses1 TheCo/pany (ses. discloses. and;or per/its access to CP"I in connection withCo/pany6initiated /arketing of services to which a c(sto/er does not alreadys(bscribe fro/ the Co/pany 'o(t6bo(nd /arketing- only p(rs(ant to the notice andapproval proced(res set forth in Sections @>1)**+. @>1)**H. and @>1)**G of the%CC0s R(les1

a1 ll o(t6bo(nd /arketing activities and ca/paigns /(st be reviewed by theCo/pany0s CP"I Co/pliance Officer for co/pliance with the CP"I restrictions andre7(ire/ents in the Co//(nications ct and the %CC R(les. and approved by the

CP"I Co/pliance Officer before they can co//ence1 Co/pany e/ployees.independent contractors and 5oint vent(re partners proposing or designing an o(t6 bo(nd /arketing ca/paign that /ay (se CP"I sho(ld initiate this CP"I review andapproval process as early as possible. for review 'pl(s the potential need to obtainc(sto/er approvals for the proposed CP"I (se- /ay take several /onths1

b1 The Co/pany /aintains appropriate paper and;or electronic records that allow itse/ployees. independent contractors and 5oint vent(re partners to clearly establish thestat(s of each c(sto/er0s O(t6o(t and;or Opt6In approvals 'if any- prior to (se of thec(sto/er0s CP"I1 These records incl(de4 'i- the date's- of any and all of thec(sto/er0s dee/ed Opt6o(t approvals and;or Opt6in approvals. together with thedates of any /odifications or revocations of s(ch approvalsB and 'ii- the type's- of CP"I (se. access. disclos(re and;or distrib(tion approved by the c(sto/er1

c1 efore a c(sto/er0s CP"I can be (sed in an o(t6bo(nd /arketing activity or ca/paign. the Co/pany0s records /(st be checked to deter/ine the stat(s of thec(sto/er0s CP"I approval1 Co/pany e/ployees. agents. independent contractorsand 5oint vent(re partners are re7(ired to notify the CP"I Co/pliance Officer of anyaccess. acc(racy or sec(rity proble/s they enco(nter with respect to these records1

d1 If new. additional or e


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e1 The Opt6O(t /echanis/ is re7(ired for c(sto/er approval4 'i- when the Co/pany

(ses CP"I to /arket services that are "OT within the sa/e 8category9 or 8package9of services to which the c(sto/er presently s(bscribes fro/ the Co/panyB and 'ii-when the Co/pany discloses CP"I to affiliates that provide co//(nications6relatedservices1 c(sto/er is dee/ed to have provided appropriate 8opt6o(t approval9 byfailing to ob5ect to the Co/pany0s 8Opt6O(t CP"I "otice9 'ttach/ent >- for atleast thirty6three '- days after notice was /ailed or e/ailed to the c(sto/er1 c(sto/er0s dee/ed 8opt6o(t approval9 is effective for a /a


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i1 E/ployees. agents. independent contractors or 5oint vent(re partners /(st notify

the CP"I Co/pliance Officer within )> ho(rs of any instance where the Opt6O(t/echanis/ does not work properly 'e.g.. where a c(sto/er clai/s that he or shenever received an Opt6O(t CP"I "otice. or where the c(sto/er clai/s that he or sheret(rned an Opt6O(t CP"I "otice denying his or her approval of the proposed CP"I(se-1 The notification shall incl(de a description of the Opt6O(t /echanis/ (sed. the proble/s e


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F1 Sh"*i'. o CPNI With Ai#i"tes1 The Co/pany will allow the CP"I for partic(lar c(sto/ers of the Co/pany0s teleco//(nications services to be accessed or (sed by.or disclosed or distrib(ted to. an ffiliate 'that is. a separate corporation. partnershipor other entity that is owned in whole or part by the Co/pany or by the owners of theCo/pany-. s(b5ect to appropriate li/itations and c(sto/er approval proced(res1

a1 If the Co/pany and ffiliate already provide a gro(p or b(ndled package of related teleco//(nications services to a partic(lar c(sto/er 'for e- for at least thirty6three '- days after notice was /ailed or e/ailedto the c(sto/er1 c(sto/er0s dee/ed 8opt6o(t approval9 is effective for a /a


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NOTE8 Co/pany e/ployees are strictly re7(ired to check the proper Co/pany files

and c(sto/er records to deter/ine whether a partic(lar c(sto/er has given his or her proper and re7(ired 8opt6in approval9 or 8opt6o(t approval9 for a partic(lar disclos(re. distrib(tion or access to CP"I to an ffiliate. and whether s(ch approvalis still effective1 E/ployees are ca(tioned that so/e c(sto/er approvals 'as well asso/e Opt6In or Opt6O(t "otices- /ay have a very narrow scope. and /ay notenco/pass a desired (se1 E/ployees are strongly disco(raged fro/ /aking their own 5(dg/ent calls to resolve (ncertainties and a/big(ities. and will bear the risk of disciplinary action if they do so and are wrong1 Rather. e/ployees are (rged to bring(ncertainties and a/big(ities to the attention of the Co/pany0s CP"I Co/plianceOfficer for appropriate resol(tion1

NOTE FURTBER8 E/ployees who split their working ti/e between the Co/panyand an ffiliate /ay not access. (se. disclose or distrib(te the Co/pany0s CP"Iwhen perfor/ing any task for or on behalf of the ffiliate. (nless the c(sto/er hasgiven the appropriate 8opt6o(t approval9 or 8opt6in approval19


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E1 Use o CPNI o* =i##i'. "') A)&i'ist*"ti-e P(*$oses

A1 =i##i'. "') Co##e!tio'1 The Co/pany0s e/ployees and billing agents /ay (se CP"I

to initiate. render. bill and collect for teleco//(nications services1 The Co/pany/ay obtain infor/ation fro/ new or e


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F1 Se!(*it% o CPNI Fi#es8 Co/pany policy /andates that

A1 %iles containing CP"I /(st be /aintained in a sec(re /anner s(ch that they cannot

be (sed. accessed. disclosed or distrib(ted by (na(thori:ed individ(als or in an(na(thori:ed /anner1

)1 Paper files containing CP"I /(st be kept in locked drawers or locked file cabinets insec(re areas. and /ay not be (sed. re/oved. or copied in an (na(thori:ed /anner1

1 Electronic files and databases containing CP"I /(st be /aintained on co/p(ters thatare not accessible fro/ the Internet or that are on the Co/pany0s intranet behindfirewalls that are reg(larly /onitored and tested for effectiveness1 In addition. s(chelectronic files and databases /ay be accessed only by a(thori:ed Co/panye/ployees who have been provided a c(rrently effective strong login I3 and

password 'which password is periodically changed-1

>1 Co/pany e/ployees. agents. independent contractors and 5oint vent(re partners arere7(ired to notify the CP"I Co/pliance Officer i//ediately by telephone or e/ail.and to provide a detailed written follow6(p /e/orand(/ within no /ore than five'F- b(siness days. of any access or sec(rity proble/s they enco(nter with respect tofiles containing CP"I1

F1 The Co/pany /(st take reasonable /eas(res to discover and protect against activitythat is indicative of prete


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VII1 Re(i*e) Ce*tii!"tio's "') Noti!es

A1 A''("# Se!tio' 41200/e3 Ce*tii!"tio'1 The Co/pany /(st file with the %CC0sEnforce/ent (rea( in E 3ocket "o1 *@6@. on or before March A of every year 'starting in)**H-. an ann(al Section @>1)**G'e- certification of co/pliance with the %CC0s CP"I R(les

'>+ C1%1R1 ??@>1)**A thro(gh @>1)*AA- d(ring the previo(s calendar year1

a1 The ann(al Section @>1)**G'e- certification /(st be signed by an Officer of the Co/panyas an agent of the Co/pany1 The Officer /(st state specifically in the certification that he or she 8has personal knowledge that the Co/pany has established operating proced(res that areade7(ate to ens(re co/pliance with the %CC0s CP"I R(les '>+ C1%1R1 ??@>1)**A thro(gh@>1)*AA-19

b1 The certification /(st be acco/panied by a separate state/ent e


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VII1 Re(i*e) Ce*tii!"tio's "') Noti!es /!o't)3

1 Se!tio' 412050/3 Noti!e to C(sto&e*s o A!!o('t Ch"'.es1 The Co/pany will notifyc(sto/ers i//ediately of certain changes in their acco(nts that /ay affect privacy or sec(rity/atters1

a1 The types of changes that re7(ire i//ediate notification incl(de4 'i- change or re7(est for change of the c(sto/er0s passwordB 'ii- change or re7(est for change of the c(sto/er0saddress of recordB 'iii- change or re7(est for change of any significant ele/ent of thec(sto/er0s online acco(ntB and 'iv- a change or re7(est for change to the c(sto/er0sresponses with respect to the back6(p /eans of a(thentication for lost or forgotten passwords1

b1 The notice /ay be provided by4 'i- a Co/pany call or voice/ail to the c(sto/er0stelephone n(/ber of recordB 'ii- a Co/pany te


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VII1 Re(i*e) Ce*tii!"tio's "') Noti!es /!o't)3

b1 Denerally. the Co/pany /ay not notify Co/pany c(sto/ers or disclose the sec(rity breach to the news /edia or p(blic for seven '+- f(ll b(siness days after it provides notice tothe United States Secret Service and to the %ederal (rea( of Investigation1 This 8black6o(t

period9 is considered very i/portant by the %CC and law enforce/ent for the s(ccess of potential or ongoing cri/inal and national sec(rity investigations. and pre/at(re c(sto/er notifications or p(blic disclos(res /ay be severely p(nished1 Moreover. law enforce/enthas the right to direct the Co/pany to e


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VIII1 Dis!i$#i'"*% P*o!e)(*es /!o't)3

Co/pany e/ployees. agents. independent contractors and 5oint vent(re partners are alsoca(tioned abo(t the dangers of both inadvertent and intentional cooperation with prete


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ATTACBMENT 5

SECTION 222 OF TBE COMMUNICATIONS ACT


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ATTACBMENT 2

FCC CPNI RULES

ATTACBMENT

SCRIPT AND FORM FOR ORAL IN=OUND MARKETING CPNI NOTICE

This "otice /(st be (sed to obtain a c(sto/er0s oral approval for (se of his or her CP"I for thed(ration of a single inco/ing call fro/ the c(sto/er to in7(ire abo(t or order new or additionalservices o(tside of his or her e


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ORAL IN=OUND MARKETING CPNI NOTICE

It is possible that I can better assist yo( on this call if I can access and (se certain of yo(r e


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ATTACBMENT

OPT?OUT CPNI NOTICE

This "otice /(st be (sed to obtain c(sto/er approval to (se CP"I for o(t6bo(nd /arketingca/paigns. and to provide or share CP"I with affiliates that provide co//(nications6relatedservices1

The "otice /ay be sent to c(sto/ers in a variety of ways. incl(ding by separate /ail. as a billinsert. by facsi/ile. or by e/ail1 The attached /odel "otice ass(/es that it will be sent by /ailor as a bill insert1

C(sto/ers /(st be allowed to disapprove by a /ethod or variety of /ethods that i/pose noadditional cost (pon the c(sto/er and that are available )> ho(rs a day1 The attached /odel "otice ass(/es that disapprovals will be /ade by /ail. facsi/ile or telephone call1

eca(se no response by a c(sto/er to an Opt6O(t "otice within days after it is sent is dee/edto constit(te the c(sto/er0s approval of the proposed CP"I (se. the %CC re7(ires the co/panyto take s(bstantial /eas(res to ens(re that Opt6O(t "otices are received. read and (nderstood byc(sto/ers1

The "otice /(st be co/prehensible to the ordinary c(sto/er. and /(st not be /isleading1 It/(st be clearly legible. (se s(fficiently large type. and be delivered in a /anner so as to bereadily apparent to the c(sto/er1 If any portion of the "otice is translated into another lang(age.the entire "otice /(st be translated into that lang(age1 If e/ail is (sed to deliver an Opt6O(t "otice. there are s(bstantial additional re7(ire/ents and preca(tions. incl(ding4 'a- c(sto/ers /(st give their e


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OPT?OUT CPNI NOTICE

W"#'(t Te#e$ho'e Co&$"'%, I'!1 )+" W"#'(t Co&&('i!"tio's is re7(esting yo(r approvalto access. (se. disclose. or distrib(te yo(r C(sto/er Proprietary "etwork Infor/ation 'or 8CP"I9- for certain p(rposes1

CP"I consists of the call. service and billing records regarding yo(r (se of theteleco//(nications services that yo( p(rchase fro/ (s 'e1g1. the telephone n(/bers yo( callB thefre7(ency. ti/ing and d(ration of yo(r callsB and the teleco//(nications and infor/ationservices yo( p(rchase-1

The Co/pany is re7(esting yo(r approval to 22222222222222222222222222222222222222222 22222222222222222222222222222222222222222222222222222222222222222222222222222 2222222222222222222222222222222222 1

!o( have a right to the confidentiality of yo(r CP"I. and the Co/pany and other carriers have ad(ty. (nder federal law. to protect that confidentiality1 !o( have a right to approve or disapprove

the proposed access. (se. disclos(re and;or distrib(tion of yo(r CP"I1

If yo( approve. the Co/pany /ay be better able to offer prod(cts and services tailored to yo(r needs1 !o(r approval will be valid for (p to two years. b(t yo( /ay revoke or li/it it at any ti/e by notifying the Co/pany in writing that yo( are doing so1

If yo( disapprove. it will not affect the provision to yo( of any of the e


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ATTACBMENT

OPT?IN CPNI NOTICE

This "otice /(st be (sed to obtain c(sto/er approval to provide or share CP"I with

independent contractors. 5oint vent(re partners and with affiliates that do not provideco//(nications6related services1

The "otice /ay be sent to c(sto/ers in a variety of ways. incl(ding by separate /ail. as a billinsert. by facsi/ile. or by e/ail1 The attached /odel "otice ass(/es that it will be sent andret(rned by /ail or facsi/ile1

The "otice /(st be co/prehensible to the ordinary c(sto/er. and /(st not be /isleading1 It/(st be clearly legible. (se s(fficiently large type. and be delivered in a /anner so as to bereadily apparent to the c(sto/er1 If any portion of the "otice is translated into another lang(age.the entire "otice /(st be translated into that lang(age1

The "otice /(st specify the entities that will receive the CP"I and the p(rpose's- for which itwill be (sed1

So/e e


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OPT?IN CPNI NOTICE

W"#'(t Te#e$ho'e Co&$"'%, I'!1 )+" W"#'(t Co&&('i!"tio's is re7(esting yo(r approvalto access. (se. disclose. or distrib(te yo(r C(sto/er Proprietary "etwork Infor/ation 'or 8CP"I9- for certain p(rposes1

CP"I consists of the call. service and billing records regarding yo(r (se of theteleco//(nications services that yo( p(rchase fro/ (s 'e1g1. the telephone n(/bers yo( callB thefre7(ency. ti/ing and d(ration of yo(r callsB and the teleco//(nications and infor/ationservices yo( p(rchase-1

The Co/pany is re7(esting yo(r approval to 22222222222222222222222222222222222222222

222222222222222222222222222222222222222222222222222222222222222222222222222222

22222222222222222222222222222222222222222222222222222222222222222222222222222 1

!o( have a right to the confidentiality of yo(r CP"I. and the Co/pany and other carriers have ad(ty. (nder federal law. to protect that confidentiality1 !o( have a right to approve or disapprovethe proposed access. (se. disclos(re and;or distrib(tion of yo(r CP"I1

If yo( approve. the Co/pany /ay be better able to offer prod(cts and services tailored to yo(r needs1 !o(r approval will be valid (ntil yo( affir/atively revoke or li/it it. which yo( /ay doin writing at any ti/e1

If yo( disapprove. it will not affect the provision to yo( of any of the e


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ATTACBMENT 4

CUSTOMER CPNI REHUEST FORM

C(sto/er "a/e222222222222222222222222222222222222 3ate222222222222222222

illing ddress 222222222222222222222222222222222222222222222222222222222222222

2222222222222222222222222222222222222222222222222222222222222222

Telephone "(/ber 2222222222222222222222222222222222222222222

CP"I Records Re7(ested 222222222222222222222222222222222222222222222222222222222

222222222222222222222222222222222222222222222222222222222222222222222222

222222222222222222222222222222222222222222222222222222222222222222222222

Ti/e Period's-. if applicable 222222222222222222222222222222222222222222222222222222

222222222222222222222222222222222222222222222222222222222222222222222222

222222222222222222222222222222222222222222222222222222222222222222222222

3eliver CP"I Records to C(sto/er via4'check one- U1S1 Mail 2222 E/ail 22222 C(sto/er #ill Pick Up 22222

If via e/ail. specify e/ail address 2222222222222222222222222222222222222222222222 '"OTE4 The Co/pany will call yo(r telephone n(/ber of record to verify the acc(racy of this e/ail address-

3eliver CP"I Records to Third Party4 "a/e and ddress of Third Party4 '"OTE4 The Co/pany will call yo(r telephone n(/ber of record and;or send a notification ofthe re7(est to yo(r address of record. to verify the acc(racy of this re7(est-

C(sto/er Signat(re 22222222222222222222222222222222 3ate 22222222222222222222222


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ATTACBMENT 7

CPNI COMPLIANCE CERTIFICATE

Se!tio' 41200/e3 o FCC R(#es

E= DOCKET NO1 04?4

I hereby certify that I a/ an Officer of #aln(t Telephone Co/pany. Inc1. and a/ e of the %ederalCo//(nications Co//ission0s R(les '>+ C1%1R1 ??@>1)**A thro(gh @>1)*AA-1

The 8State/ent E


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E- /aintaining records regarding the (se of CP"I in /arketing ca/paignsB and 'F-receiving. reviewing and resolving 7(estions or iss(es regarding (se. disclos(re. distrib(tionor provision of access to CP"I1


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Co/pany e/ployees and agents that /ay deal with CP"I have been infor/ed that there ares(bstantial federal restrictions (pon CP"I (se. distrib(tion and access1 In order to bea(thori:ed to (se or access the Co/pany0s CP"I. e/ployees and agents /(st receive trainingwith respect to the re7(ire/ents of Section ))) of the Co//(nications ct and the %CC0sCP"I R(les 'S(bpart U of Part @> of the %CC R(les-1

efore an agent. independent contractor or 5oint vent(re partner /ay receive or be allowed toaccess or (se the Co/pany0s CP"I. the agent0s. independent contractor0s or 5oint vent(re partner0s agree/ent with the Co/pany /(st contain provisions 'or the Co/pany and theagent. independent contractor or 5oint vent(re partner /(st enter into an additionalconfidentiality agree/ent which provides- that4 'a- the agent. independent contractor or 5ointvent(re partner /ay (se the CP"I only for the p(rpose for which the CP"I has been providedB 'b- the agent. independent contractor or 5oint vent(re partner /ay not disclose or distrib(te the CP"I to. or allow access to the CP"I by. any other party '(nless the agent.independent contractor or 5oint vent(re partner is e


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>1 Co/pany e/ployees will a(thenticate all telephone re7(ests for CP"I in the sa/e /anner whether or not the CP"I consists of call detail infor/ation1 That is. Co/pany e/ployees/(st4 'a- be f(rnished the c(sto/er0s pre6established password 'or correct answers to the back6(p 8shared secret9 co/binations-B 'b- send the re7(ested infor/ation to the c(sto/er0s postal or electronic 8address of record9 'see definition above-B9 or 'c- call the c(sto/er back

at the c(sto/er0s 8telephone n(/ber of record9 'see definition above- with the re7(estedinfor/ation1

F1 If a c(sto/er s(bscribes to /(ltiple services offered by the Co/pany and an affiliate. theCo/pany is per/itted to share the c(sto/er0s CP"I regarding s(ch services with its affiliate1If a c(sto/er does not s(bscribe to any teleco//(nications or non6teleco//(nicationsservices offered by an affiliate. the Co/pany is not per/itted to share the c(sto/er0s CP"Iwith the affiliate witho(t the c(sto/er0s consent p(rs(ant to the appropriate notice andapproval proced(res set forth in Sections @>1)**+. @>1)**H and @>1)**G of the %CC0s R(les1 @1 #hen an e1)**H'f- of the %CC0s R(les and after the Co/pany a(thenticates the c(sto/er1

The Co/pany /ay disclose or release call detail infor/ation to c(sto/ers d(ring c(sto/er6initiated telephone contacts only when the c(sto/er provides a pre6established password1 If the c(sto/er does not provide a password. call detail infor/ation can be released only bysending it to the c(sto/er0s address of record or by the carrier calling the c(sto/er at thetelephone n(/ber of record1 If the c(sto/er is able to provide to the Co/pany d(ring ac(sto/er6initiated telephone call. all of the call detail infor/ation necessary to address ac(sto/er service iss(e 'i.e1. the telephone n(/ber called. when it was called. and. if applicable. the a/o(nt charged for the call- witho(t Co/pany assistance. then the Co/pany/ay take ro(tine c(sto/er service actions related to s(ch infor/ation1 '=owever. (nder thiscirc(/stance. the Co/pany /ay not disclose to the c(sto/er any call detail infor/ationabo(t the c(sto/er acco(nt other than the call detail infor/ation that the c(sto/er provideswitho(t the c(sto/er first providing a password1-


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AA1 The Co/pany0s e/ployees and billing agents /ay (se CP"I to initiate. render. bill andcollect for teleco//(nications services1 The Co/pany /ay obtain infor/ation fro/ new or e


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AH1 The Co/pany /ay per/it its c(sto/ers to establish online acco(nts. b(t /(st re7(ire anappropriate password to be f(rnished by the c(sto/er before he or she can access any CP"Iin his or her online acco(nt1 S(ch password /ay "OT be based (pon readily obtainable biographical infor/ation 'e.g.. the c(sto/er0s na/e. /other0s /aiden na/e. social sec(rityn(/ber or date of birth- or acco(nt infor/ation 'e.g.. the c(sto/er0s telephone n(/ber or

address-1

AG1 C(sto/ers /ay obtain an initial or replace/ent password4 'i- if they co/e in person tothe Co/pany0s b(siness office. prod(ce a driver0s license. passport or other govern/ent6iss(ed identification verifying their identity. and correctly answer certain 7(estions regardingtheir service and addressB or 'ii- if they call a specified Co/pany telephone n(/ber fro/their telephone n(/ber of record. and then wait at that n(/ber (ntil a Co/panyrepresentative calls the/ back and obtains correct answers to certain 7(estions regardingtheir service and address1

)*1 The Co/pany will notify c(sto/ers i//ediately of certain changes in their acco(nts that

/ay affect privacy or sec(rity /atters1

a1 The types of changes that re7(ire i//ediate notification incl(de4 'a- change or re7(estfor change of the c(sto/er0s passwordB 'b- change or re7(est for change of thec(sto/er0s address of recordB 'c- change or re7(est for change of any significant ele/entof the c(sto/er0s online acco(ntB and 'd- a change or re7(est for change to thec(sto/er0s responses with respect to the back6(p /eans of a(thentication for lost or forgotten passwords1

b1 The notice /ay be provided by4 'a- a Co/pany call or voice/ail to the c(sto/er0stelephone n(/ber of recordB 'b- a Co/pany te


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)A1 The Co/pany /(st provide an initial notice to law enforce/ent and a s(bse7(ent noticeto the c(sto/er if a sec(rity breach res(lts in the disclos(re of the c(sto/er0s CP"I to a third party witho(t the c(sto/er0s a(thori:ation1

a1 s soon as practicable 'and in no event /ore than seven '+- days- after the Co/pany

discovers that a person 'witho(t a(thori:ation or e


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IV1 CPNI Co&$#i"'!e Oi!e*

In addition to the specific /atters re7(ired to be reviewed and approved by the Co/pany0sCP"I Co/pliance Officer. e/ployees and agents. independent contractors and 5oint vent(re partners are strongly enco(raged to bring any and all other 7(estions. iss(es or (ncertainties

regarding the (se. disclos(re. or access to CP"I to the attention of the Co/pany0s CP"ICo/pliance Officer for appropriate investigation. review and g(idance1 The e


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E


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