ANNUAL 47 CER, § 64.2009(e) CPNI Certification EB Docket 06:36 Annual 64,2000) CPNI Certification for 2011 covering the prior calendar year 2010 1. Dae filed: 02/21/2011 2 Name of company covered by this certification: ‘Washington County Rural Telephone Coopertve, lc 3. Foxm 499 Filer ID: 808455 4. Name of sigmaty: Roland King 5. Tile of signatory: President 6 Coniston 1, Roland King cerify tha am an officer of the company named above, and acting 38 an agent ‘of the company, that Ihave personal knowledge thatthe company has established operating procedures {hat ae adequate o ensure compliance with the Commission's CPNI ules. See 47 CFR. § 64.2001 et se. Atiched to this cenieation is an accompanying statement explaining how the company’s procedures ensure that the company is in compliance withthe requirements (including those mandating the adoption of CPNI procedures, taining, recordkeeping, and supervisory review) set forth in section {64,2001 et seq, ofthe Commission rules. ‘The company has not taken actions (.c. proceedings instituted or petitions filed by a company at either sate commissions, the court system, or at the Commission against data brokers) against data brokers in the past year ‘The company has not recsived customer complaints inthe past year concerning the unauthorized release of CPNL “The company represents and warrants thatthe above certification is consistent with 47 CER. § LIT which requies tuhful and. accurate statements to the Commission, The company also acknowledges that false statements and misrepresentations tothe Commission ae punishable under Title 18 ofthe US, Code and may subject it to enforcement action Signed: he 4 Dae: FFB Io [Autchment: Accompanying Statement explaining CPNI procedures‘Statement of dures Attachment: Accompany Per the FOC CPNI rules (47 CFR §64.2009(e)] and as referenced in the altached signed ‘certification, Washington County Rural Telephone Cooperative, Inc. dib/a Tele-Media Solutions, herein referenced as the Company hereby certifies that the Company [and Its affiates) is in compliance with the FCC CPNI rules and has outlined some of the important ‘operating procedures below in ord to ensure the Company's compliance in the protection of CPNI: 4, CPNI manual has been updated inorder to account for all FCC GPNI rules, including the recent ‘visions, and has been adopted by our Company's board 2. CPNI Complance ofcer has been designated to oversee all CPNI utes, taining, and activity © Established an outbound markelng supervisory review process forthe use of CPN Records ere maintained for ny marketing campalgns that ulize customers! CPNI for minimum of one year 3, Employees have been trained on when they are, and are not, authorized to use or disclose CPNI Discpinary process hes been defined and isin place for velations andlor breaches of cent 4. Carir authentication raquirements have been met 12 Al cistomer during @ customornitated telephone call are authenticated as being an aunorized account contact before discussing CPN! (non-cal detail or cll detl) without Utzing ready avatable biographical or account information as defined bythe FCC. ‘2 Call deta is only released to customers during customersnatedtolophone contact a password fs proves. the roquesting customor doos not provide a password, only the folloning FC approved mathods are permited forte reloaseof the requested cal deal 1 Sending the requested dated to the address of record (ony a physical of email fsddress asociotes with that parcular aecount tel es Boon inoue eompany es for at east 30 aye) + Caling the customer back at the telephone of record (only disclosing i the ‘customer was authenticated as being an authorized account contact) 1+ Having customer come in lo Company's offce and provide @ val government Issued photo ID 5. Notice to customer of account change as customers are nied immediately when a customer ‘Creates or changes one ofthe following: password 'SGuslomer response o@ back-up means of authentication for lost o forgotton passwords online secount sds of record 6. Notice of unauthorized dscosure of CPNI, a notification process in place in order to notiy both law enforcement and cusiomer(s) in the event of a CPNI breach within the timeline species by the FOC 7 Opt metodo approve Celso for marci campaigns wed Customers are noiied branously Of ter rights forthe use oftheir CPNI in marketing compsigns ‘9 New customers are notified ofthe opt-out procedure as a part of tho customer sign-up process © _Biling system displays customer's opting status ‘Compliance officer retains CPNI notations and opting recor for at least two years {8 Adcitonal protection measures are taken above and beyond the curent FCC CPNI rues ‘© Company takes reasonable measures to discover and protect against activity that is Indicative of pretexting ‘2 Company maintains security of ll CPN, incucing but not ted to: + "Documents containing CPNI are shredsod 1 Computer teminals ae locked when employee is not atthe station