CPNI Certifications Due No Later Than March 1, 2020
CPNI Certifications Due No Later Than March 1, 2020
___________________________________________________
Telecommunications carriers, including interconnected Voice over Internet Protocol (“VoIP”) providers, are required to establish and maintain systems designed to ensure they protect their subscribers’ Customer Proprietary Network Information (“CPNI”) and must file an annual CPNI compliance certification no later than March 1, 2020[1](for data pertaining to the previous calendar year).
The certification filing can be electronically submitted in EB Docket No. 06-36 of the FCC’s Electronic Comment Filing System or by using the FCC’s online CPNI web page at: http://apps.fcc.gov/eb/CPNI/index.cfm.
- If filing in the docket, 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.
- If filing on the FCC’s CPNI web page, carriers must complete the CPNI template, which includes the same certification information to be included in a docket submission, and must upload attachments 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.
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 [email protected] or Robin Tuttle at [email protected].
___________________________________________________
