Attachment A

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Attachment A

Statement Concerning Procedures Ensuring Compliance with CPNI Rules


The operating procedures of United Telephone Company dba United Communications (Form 499
Filer ID No. 809151) and UTC Long Distance (Form 499 Filer ID No. 817236 (the Company) ensure
that the Company complies with Part 64, Section 2001 et.seq. of the FCC rules governing the use of
Customer Proprietary Network Information (CPNI).
The Company has established a system by which the status of a customers approval for the use of
CPNI can be clearly established prior to the use of CPNI. The Company relies on the involvement of
its supervisor/management to ensure that no use of CPNI is made without review of applicable rules
and law.
The Company trains its personnel regarding when they are authorized to use CPNI, as well as when
they are not authorized to use CPNI. Personnel must sign a verification form stating they have
completed training and understand that any infraction of the CPNI procedures can result in disciplinary
action being taken against them.
The Company has an express disciplinary process in place for personnel who create or are involved
in an infraction of the CPNI rules and the Companys CPNI Operating Procedures.
The Company maintains records of its own sales and marketing campaigns via a log. These records
include a description of each campaign, the specific CPNI used in the campaign, and the products and
services that were offered as a part of the campaign. The Company has a supervisory review process
for all outbound marketing. The marketing campaign log requires a supervisor to review, sign and date
the log. These records are maintained for a minimum of one year.
The Company maintains records of customer approval for the use of CPNI that include a copy of
the notice and the customers opt-out written notification. These records are maintained for a
minimum of one year.
The Company requires that customers be authenticated at the beginning of all customer initiated
calls, online transactions, or in-store visit. In store visits require a valid photo ID.
The Company maintains a log of unauthorized use of CPNI, where law enforcement is required to
be notified. This includes the date of discovery, notification to law enforcement, description of the
breach, circumstances of the breach and a supervisors signature and date. This log is maintained for a
minimum of two years.

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