VoIPConsultants FCC CPNI Policy 2015

STATEMENT OF POLICY IN TREATMENT OF CUSTOMER
PROPRIETARY NETWORK INFORMATION
1. It is VoIPConsultants.biz, LLC. (hereafter referred to as VoIPConsultants) policy

not to use CPNI for any activity other than permitted by law. Any disclosure of
CPNI to other parties (such as affiliates, vendors, and agents) occurs only if it is
necessary to conduct a legitimate business activity related to the services
already provided by the company to the customer. If the Company is not required
by law to disclose the CPNI or if the intended use does not fall within one of the
carve outs, the Company will first obtain customers consent prior to using CPNI.
2. VoIPConsultants follows industry-standard practices to prevent unauthorized
access to CPNI by a person other than the subscriber or VoIPConsultants.
However, VoIPConsultants cannot guarantee that these practices will prevent
every unauthorized attempt to access, use, or disclose personally identifiable
information. Therefore:
a. If an unauthorized disclosure were to occur VoIPConsultants shall provide
notification of the breach within seven (7) days to the United States Secret
Service (USSS) and the Federal Bureau of Investigation (FBI).
b. VoIPConsultants shall wait an additional seven (7) days from its
government notice prior to notifying the affected customers of the breach.
c. Notwithstanding the provisions in subparagraph B above, VoIPConsultants
shall not wait the additional seven (7) days to notify its customers if
VoIPConsultants determines there is an immediate risk of irreparable
harm to the customers.
d. VoIPConsultants shall maintain records of discovered breaches for a
period of at least two (2) years.
3. All employees will be trained as to when they are, and are not, authorized to use
CPNI upon employment with the Company and annually thereafter.
a. Specifically, VoIPConsultants shall prohibit its personnel from releasing
CPNI based upon a customer-initiated telephone call except under the
following three (3) circumstances:
i. When the customer has a pre-established password.
ii. When the information requested by the customer is to be sent to
the customers address of record, or
1
iii. When VoIPConsultants calls the customers telephone number of

record and discusses the information with the party initially
identified by customer when service was initiated.
b. VoIPConsultants may use CPNI for the following purposes:
i. To initiate, render, maintain, repair, bill and collect for services;
ii. To protect its property rights; or to protect its subscribers or other
carriers from fraudulent, abusive, or the unlawful use of, or
subscription to, such services;
iii. To provide inbound telemarketing, referral or administrative
services to the customer during a customer initiated call and with
the customers informed consent;
iv. To market additional services to customer that are within the same
categories of service to which the customer already subscribes;
v. To market services formerly known as adjunct-to-basic services;
and,
vi. To market additional services to customers with the receipt of
informed consent via the use of opt-in or opt-out, as applicable.
4. Prior to allowing access to Customers individually identifiable CPNI to
VoIPConsultants joint venturers or independent contractors, VoIPConsultants will
require, in order to safeguard that information, their entry into both confidentiality
agreements that ensure compliance with the Statement and shall obtain opt-in
consent from a customer prior to disclosing the information. In addition,
VoIPConsultants requires all outside Dealers and Agents to acknowledge and
certify that they many only use CPNI for the purpose for which that information
has been provided.
5. VoIPConsultants requires express written authorization from the customer prior
to dispensing CPNI to new carriers, except as otherwise required by law.
6. VoIPConsultants does not market, share or otherwise sell CPNI information to
any third party.
7. VoIPConsultants maintains a record of its own and its affiliates sales and
marketing campaigns that use VoIPConsultants customers CPNI. The record
will include a description of each campaign, the specific CPNI that was used in
the campaign, and what products and services were offered as part of the
campaign.
a. Prior to commencement of a sales or marketing campaign that utilizes
CPNI, VoIPConsultants establishes the status of a customers CPNI
approval. The following sets forth the procedure followed by

VoIPConsultants;
i. Prior to any solicitation for customer approval VoIPConsultants will
notify customers of their right to restrict the use of, disclosure of,
and access to their CPNI.
ii. VoIPConsultants will use opt-in approval for any instance in which
VoIPConsultants must obtain customer approval prior to using,
disclosing, or permitting access to CPNI.
iii. A customers approval or disapproval remains in effect until the
customer revokes or limits such approval or disapproval.
iv. Records of approvals are maintained for at least one year.
v. VoIPConsultants provides individual notice to customers when
soliciting approval to use, disclose, or permit access to CPNI.
vi. The content of VoIPConsultants CPNI notices comply with FCC
rule 64.2008 (c).
8. VoIPConsultants has implemented a system to obtain approval and informed
consent from its customers prior to use of CPNI for marketing purposes. This
system allows for the status of customers CPNI approval to be clearly
established prior to the use of CPNI.
9. VoIPConsultants has supervisory review process regarding compliance with the
CPNI rules for outbound telemarketing situations and will maintain compliance
records for at least one year. Specifically, VoIPConsultants sales personnel will
obtain express approval of any proposed outbound marketing request for
customer approval of the use of CPNI by The General Counsel of
VoIPConsultants.
10. VoIPConsultants notifies customers immediately of any account changes,
including address of record, authentication, online account and password related
changes.
11. VoIPConsultants may negotiate alternative authentication procedures for
services that VoIPConsulants provides to business customers that have a
dedicated account representative and a contract that specifically address
VoIPConsultants protection of CPNI.
12. VoIPConsultants is prepared to provide written notice within five business days to
the FCC of any instance where the opt-in mechanisms do not work properly to
such a degree that consumers inability to opt-in is more than an anomaly.

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STATEMENT OF POLICY IN TREATMENT OF CUSTOMER

PROPRIETARY NETWORK INFORMATION

1. It is VoIPConsultants.biz, LLC. (hereafter referred to as VoIPConsultants) policy

iii. When VoIPConsultants calls the customers telephone number of

approval. The following sets forth the procedure followed by

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