ANNUAL CPNI COMPLIANCE CERTIFICATIONS DUE MARCH 1, 2019

Telecommunications carriers, including Voice over Internet Protocol (“VoIP”) providers, must file annual Customer Proprietary Network Information (“CPNI”) compliance certifications by Friday, March 1, 2019 (for data pertaining to the previous calendar year).  Carriers must include a statement explaining how their operating procedures are in compliance with the CPNI rules and any actions taken against data brokers, as well as a summary of all customer complaints received in the past year concerning the unauthorized release of CPNI.  The certification must be signed by an officer having personal knowledge that the company’s operating procedures are adequate to ensure compliance with the CPNI rules.

Broadband Internet access service (“BIAS”) providers remain subject to the customer privacy provisions in Section 222 of the Communications Act, pursuant to the 2015 Open Internet Order and the FCC’s enforcement advisory.  BIAS providers should continue to employ effective privacy protections in line with their privacy policies and the core tenets of basic privacy protections, but need not file a CPNI compliance certification.

If you would like assistance with preparing and filing this annual CPNI compliance certification, or if you have any questions regarding CPNI compliance, please contact Greg Whiteaker at greg@hermanwhiteaker.com or Robin Tuttle at rtuttle@hermanwhiteaker.com.