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KINGDOM TELECOMMUNICATIONS, INC.

Policy on Customer Propriet ry Net!or" In#orm tion $CPNI% &ritten Policy D te' April ()*) The explanation and policy below is meant to set rules for all employees of Kingdom Telecommunications, Inc. (KTI) on the use of !"I. There will be no use of !"I for any mar#eting purposes by any employee(s) of the company without following the guidelines set forth below. $ailure to follow these guidelines will result in disciplinary action ta#en against any %iolator of this policy. APPLICA+LE ,ULES & $ 'ection ((((f) & )o!' * '+ (*,-.../0,

1ccording to $ and )o!' regulations, a telecommunications carrier may not use, disclose, or permit access to CPNI to market to a customer, service offerings that are within a category of service to which the customer does not already subscribe to from that carrier, unless the carrier has customer approval to do so &-AT IS CPNI. +egulations of the $ 2 )o!' state that !"I means3

1. Information that relates to the 4uantity, technical configuration, type, destination and amount of use of a telecommunications ser%ice subscribed to by any customer of a telecommunications carrier and that is made a%ailable to the carrier by the customer solely by the %irtue of the carrier-customer relationship. 5. Information contained in the bills pertaining to telephone exchange or toll ser%ice recei%ed by a customer of a carrier6 except that such term does not include subscriber list information. In practical terms, !"I is pri%ate information held only by KTI through its business relationship with the customer that re%eals3 1. 7here, when and to whom they call 5. 1mount and length of calls they ma#e . 'er%ices they subscribe to (calling features, etc.) 8. 7ho their pro%ider is for a gi%en ser%ice &-AT IS NOT CPNI. 1. !ublished directory information such as a customer9s name, address, and telephone number 5. Information that is a%ailable in the public domain or from any other, non-company source . Information you gather from customers in ways other than through the pro%ision of ser%ice 8. Information deri%ed from sales of !: or information ser%ices :. ustomer credit information $. !roducts on bill that are not telecommunications ser%ices

+E/O,E ,ELEASING AN0 CPNI IN/O,MATION T-E /OLLO&ING SA/EGUA,DS A,E ,E1UI,ED +0 T-E /CC The CC CPNI rules guard against prete!ting "pretending to #e a customer or authori$ed person in order to access call detail or other private information% and protect &TI customers against unauthori$ed access and disclosure of their information' 1. The following rules are established for customer calls, online account access, and inoffice contacts3 7e are prohibited from releasing call detail information during customerinitiated calls except under the following circumstances. ustomer pro%ides a pre-established password !"I is mailed to the address of record 7e call customer at the telephone number of record E2CEPT - If our customer pro%ides all the call detail information needed to address an issue, without our assistance, we can discuss that call without %iolating !"I rules. E2CEPT & If KTI9s contract with a business customer has specific !"I pro%isions and is ser%iced by a dedicated account representati%e. !assword reation 7e must establish a password when ser%ice is initiated. This should include a bac#up password process for when the password of record is forgotten. The bac#up password is a shared secret of one or more 4uestion-answer combinations that are #nown to the customer and the carrier but are not widely #nown. It is ot3er!ise ille4 l for KTI employees to assist the customer with their password by prompting them in any way. $or existing customers, we can only establish a password by contacting the customer at their telephone number. 7e CANNOT authenticate a customer to create passwords by using a%ailable biographical information or account information when they call our office. $or a customer that comes to the office we can %erify their right to !"I by chec#ing a %alid photo I8. 1lternati%e ustomer 1ccess 7ithout !assword 7e can send the customer the call detail information and other !"I to their mailing address of record 7e can call the telephone number of record ;nline 1ccess KTI pro%ides mandatory password protection for online account access 7e are prohibited from relying on readily a%ailable account or biographical information to authenticate a customer9s identity before a customer accesses !"I online )ust authenticate both existing and new customers see#ing online access. 7e do not ha%e to reinitiali<e existing online passwords or customers seeking assistance with their on(line account, we can communicate with them via email at their ktis'net account if no prior customer service password for authentication has #een esta#lished' The customer could reply to our email with a password that then could #e used for assisting that customer'

5. 7hen there are customer account changes %erbally through our office we must notify our customer immediately if the following information is changed. !assword ustomer bac#-up means for lost or forgotten password ;nline account 1ddress of record !"I3

. In case of an unauthori<ed disclosure of

1 log must be #ept by the senior '+, on a calendar year basis, that shows all customer complaints of unauthori<ed release of !"I recei%ed in the period. If a breach is disco%ered the retained records must include the date the =.'. 'ecret 'er%ice (=''') and the $5I were notified, a detailed description of the !"I that was breached, and the circumstances of the breach. +etain this log for at least ( years. 1 notification to law enforcement must happen within se%en (>) days of the breach. This notification can be accomplished %ia the $ lin# at www.fcc.go%?eb?cpni ustomers must also be notified within se%en (>) days ="@:'' the =''' or the $5I re4uest that notification be held for up to thirty(.,) days in writing. They may also re4uest additional thirty(.,) day extensions in writing.

O5E,5IE& O/ CPNI ,ULES 1. KTI is permitted to use !"I, without customer approval, to mar#et offerings that are related to, but limited by, the customers existing service relationship. Those relationships would be3 Telecommunications 'er%ices @ocal 'er%ice Kingdom @ong 8istance Inside 7iring "on-telecommunications 'er%ices Information 'er%ices Internet 1ccess !"I for the following without special customer permission.

KTI can use

"on-mar#eting purposes including3 Initiation and billing of ser%ice !rotection against fraud "etwor# !lanning "ormal customer ser%ice calls (billing, etc.) )ar#eting !: and Information 'er%ices )ar#eting inside wiring installation, maintenance and repair To win bac# customers who switched to another carrier )ar#eting of ser%ices within categories in which customer already is a subscriber

B. 5efore KTI may use !"I to mar#et outside the customer)s e!isting service

relationship, we must gi%e our customers the opportunity to opt-out of ha%ing KTI mar#et those ser%ices to them. New customers are advised of their privacy rights related to CPNI upon esta#lishing service. 1dditionally, opt-out notices will be mailed out e%ery two years to all customers. (1ll written notification must use at least a /, point font.) 1cti%e customers, choosing to opt-out of any !"I mar#eting, ha%e had their customer file updated to include a ='; establishing their account as a 6,estricte7 CPNI8 customer account.

KTI will provide written notification to the PSC within five (5) business days of any instance where the opt-out mechanisms do not wor properly!
$or !"I disclosure to unrelated third parties or to any KTI affiliate, a customer must opt-in to allow that information to be pro%ided. T-IS &ILL NOT +E DONE &IT-OUT MANAGEMENT9S APP,O5AL O/ SUC- A DISCLOSU,E. . The $ 2 )o!' ha%e implemented certain safeguards to protect !"I from unauthori<ed distribution or access. KTI is adopting these safeguards as a part of its !"I policy. 1ppro%al Trac#ing KTI will retain customer9s !"I opt-out directi%es by posting those on the customer9s account as +estricted !"I. 1ll documents related to any mar#eting campaign using !"I, will be filed in the !"I $older in the 1dministrati%e 1ssistant9s file system for no less than one year. :mployee Training 1ll employees with access to customer records will #now rules applying to !"I 7hat is !"I 7hen they can use !"I and when they cannot use !"I 1ny %iolation of this policy will result in immediate termination ompliance ertificate 1nnual, signed by corporate officer, and due the $ by )arch /st and the )o!' in 1nnual +eport by 1pril /Ath. ertification must include an accompanying statement explaining how KTI9s operating procedures ensure compliance with the rules, a detailed explanation of any actions ta#en against data bro#ers (if any), and a summary of all customer complaints recei%ed in the past year concerning the unauthori<ed release of !"I. ertification will include a statement that KTI9s operating procedures are in compliance with the !"I rules and include an accompanying statement that details how the carrier9s procedures are not in compliance if applicable. This certification will be a%ailable to public 'uper%isory +e%iew )ar#eting campaigns, using !"I, must be appro%ed in ad%ance by the Beneral )anager. 1ll records for outbound mar#eting situations must be retained for a minimum of one year. The record must include a description of each campaign, the specific !"I that was used in the campaign, and what products and ser%ices offered as part of the campaign.

SUMMA,0 O/ CPNI IMPACT KTI maintains a record, electronically or in some other manner, of its own, its agents9, its affiliates9, its Coint %enture partners9 or its independent contractors9 sales and mar#eting campaigns that use !"I. These records include any instances where !"I was disclosed or pro%ided to third parties or where third parties were allowed access to !"I. +ecords include a description of each campaign, the specific !"I that was used in the campaign, and what products or ser%ices were offered as a part of the campaign. 'uch records are retained for all current and former customers for a minimum of one (/) year!

One:time use

ppro; ls

;n an inbound (after proper authentication) or normal course of business outbound call, you can loo# at !"I and mar#et new ser%ices to a customer if you receive oral approval to do so #efore marketing the service and their file does not indicate *estricted CPNI. If KTI were to do a targeted telephone mar#eting campaign, our responsibility as part of the appro%al process should be3 )ust state that the customer has a right, and that KTI has a duty, under federal law, to protect the confidentiality of their !"I. (";T:3 If they want to restrict !"I, we must do that immediately without further mar#eting discussions) )ust specify the types of information that constitute !"I )ust describe the purposes for which !"I will be used )ust state the appro%al is for the length of the call only )ust be clear to the customer and not misleading The call may state that use of !"I will enhance KTI9s ability to offer products and ser%ices tailored to the customer9s needs.

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