8/9/2019 RGSI 2015 CPNI Certification and Attachment A.pdf
http://slidepdf.com/reader/full/rgsi-2015-cpni-certification-and-attachment-apdf 1/8
TAI LAW GROUP PLLC
Christopher C. Tai 1330 Connecticut Avenue, NW
[email protected] Washington, D.C. 20036
Tel. 202.480.9810
February 21, 2015
Marlene H. Dortch
Office of the SecretaryFederal Communications Commission
445 12th
Street, SWSuite TW-A325
Washington, DC 20554
Re: Reliance Globalcom Services, Inc. CPNI CertificationEB Docket No. 06-36
Dear Ms. Dortch:
As required under Section 64.2009(e) of the Commission’s Rules, 47 C.F.R. § 64.2009(e)
and Public Notice DA 15-178 please find enclosed a certificate of compliance with the
Commission’s Customer Proprietary Network Information regulations submitted on behalf of
Reliance Globalcom Services, Inc. (“RGSI”) and signed by RGSI’s Executive Vice President.
Should you have any questions, please do not hesitate to contact the undersigned.
Respectfully submitted,
/s/
_______________________________
Christopher C. TaiColleen A. Sechrest
Counsel for Reliance Globalcom Services, Inc.
Enclosure as stated
cc: Best Copy and Printing, Inc. (one copy via email)
8/9/2019 RGSI 2015 CPNI Certification and Attachment A.pdf
http://slidepdf.com/reader/full/rgsi-2015-cpni-certification-and-attachment-apdf 2/8
Annual 47 C.F.R. 64.2009(e) CPNI Certificate
EB Docket No. 06-36
Annual 64.2009(e) CPNI Certification for 2015 covering the prior calendar year 2014
Date filed: February 21, 2015
Name of company covered by this certification: Reliance Globalcom Services, Inc.
Form 499 Filer ID: 823022
Name of signatory: Janet Troxell
Title of signatory: Executive Vice President
I, Janet Troxell, certify that I am the E xecutive Vice President for Reliance
Globalcom Services, Inc. ( RGS I ) and, acting as an agent of RGSI, that I have personal
knowledge that the com pany has established operating procedures (described in Attachment A)
that are adequate to ensure that RGSI is in com pliance with the Commission's CPNI rules. See
47 C.F.R. § 64.2001 et seq
Attached to this certification is an accom panying statement explaining how
RGSI's procedures ensure that RGSI is in compliance with the requirements (including those
mandating the adoption of CPNI procedures, training, recordkeeping, and supervisory review)
set forth in Section 64.2001
et seq
of the Commission's rules.
See Attachment A.
RGSI has not taken any actions
i.e.
proceedings instituted or petitions filed at
either state commissions, the court system, or at the Com mission against data brokers) against
data brokers in the past year.
8/9/2019 RGSI 2015 CPNI Certification and Attachment A.pdf
http://slidepdf.com/reader/full/rgsi-2015-cpni-certification-and-attachment-apdf 3/8
RGSI has not received any customer complaints in the past year concerning the
unauthorized release of CPNI.
RGSI represents and warrants that the above certification is consistent with 47 C.F.R.
§1.17 which requires truthful and accurate statements to the Commission. The company also
acknowledges that false statements and misrepresentations to the Commission are punishable
under Title 18 of the U.S. Code and may subject it to enforcement action.
Janet oxell
Executive Vice President
Reliance Globalcom Services Inc.
Date:
a
2015
8/9/2019 RGSI 2015 CPNI Certification and Attachment A.pdf
http://slidepdf.com/reader/full/rgsi-2015-cpni-certification-and-attachment-apdf 4/8
TT CHMEN
T
ST TE
MENT OF CP
NI COMPLI
NCE PROCED
URES
1
It is Relian
ce Globalcom S
ervices, Inc. (
RGSI ) policy
not to use CPN
I for any activit
y
othe
r than permitted
by law. Any d
isclosure of CP
NI to other par
ties (such as af
filiates,
ve
ndors and agent
s) occurs only i
f it is necessary
to conduct a le
gitimate busines
s activity
related to
the services al
ready provided
by RGSI to the
customer. If RG
SI is not requi
red
by la
w to disclose
the CPNI or i
f the intended
use does not f
all within one
of the
regulatory c
arve-outs, RGS
I will first obta
in the customer
s consent prior
to using CPNI.
2
RGSI fo
llows industry-
standard practi
ces to prevent
unauthorized a
ccess to CPNI b
y a
perso
n other than th
e subscriber or
RGSI. Howev
er RGSI canno
t guarantee tha
t these
practices w
ill prevent eve
ry unauthorize
d attempt to ac
cess use or dis
close personal
ly
i
dentifiable info
rmation. Theref
ore:
a
If an unauth
orized disclos
ure occurs RG
SI shall prov
ide notification
of the
breach within seven (7) days to the United States Secret Service and the Federal
Bureau of In
vestigation
b
RGSI shall
wait an additio
nal seven (7) d
ays from its go
vernment notic
e prior to
notifyin
g the affected c
ustomers of the
breach
c
Notwithstandin
g the provision
s in subparagr
aph (b) above,
RGSI shall not
wait
the a
dditional seven
(7) days to no
tify its custome
rs if RGSI dete
rmines there is
an im m ediate risk of ir reparable harm to the cust omers.
d
RGS
I shall maintain
records of disc
overed breache
s for a period o
f at least two (2
)
years
8/9/2019 RGSI 2015 CPNI Certification and Attachment A.pdf
http://slidepdf.com/reader/full/rgsi-2015-cpni-certification-and-attachment-apdf 5/8
3
ll employees will be trained as to when they are, and are not, authorized to use CPNI
upon employment with RGSI and annually thereafter.
a. Specifically, RGSI 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 pre-established a password.
ii
When the information requested by the customer is to be sent to the
customer s address of record; or
iii
When RGSI calls the customer s telephone number of record and
discusses the information with the party initially identified by customer
when service w as initiated
b. RGSI 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 customer s
informed consent;
iv
To market additional services to customers 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
8/9/2019 RGSI 2015 CPNI Certification and Attachment A.pdf
http://slidepdf.com/reader/full/rgsi-2015-cpni-certification-and-attachment-apdf 6/8
vi. To market additional services to customers with the receipt of informed
consent via the use of opt-in or opt-out elections as applicable.
4
Prior to allowing access to customers individually identifiable CPNI to RGSI s joint
venturers or independent contractors, RGSI will require, in order to safeguard that
information, their entry into both confidentiality agreements that ensure compliance with
this Statement and shall obtain opt-in consent from a customer prior to disclosing the
information. In addition, RGSI requires all outside dealers and agents to acknowledge
and certify that they may only use CPNI for the purpose for which that information has
been provided
5
RGSI requires express written authorization from the customer prior to disclosing CPNI
to new carriers except as otherwise required by law.
6 RGSI does not market share or otherwise sell CPNI to any third party.
7 RGSI maintains a record of its own and its affiliates sales and marketing campaigns that
use RGSI s 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,
RGSI establishes the status of a customer s CPNI approval. The following sets
forth the procedure followed by RGSI
i. Prior to any solicitation for customer approval, RGSI will notify
customers of their right to restrict the use of, disclosure of, and access to
their CPNI
8/9/2019 RGSI 2015 CPNI Certification and Attachment A.pdf
http://slidepdf.com/reader/full/rgsi-2015-cpni-certification-and-attachment-apdf 7/8
ii.
RGSI will use opt-in approval for any instance in which RGSI must obtain
customer approval prior to using, disclosing, or permitting access to CPNI.
iii.
A customer s 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
RGSI provides individual notice to customers when soliciting approval to
use, disclose, or permit access to CPNI.
vi.
The content of RGSI s CPNI notices comply with FCC rule 64.2008(c).
8
Reliance has implemented a system to obtain approval and informed consent from its
customers prior to the use of CPNI for marketing purposes. This system allows for the
status of a customer s CPNI approval to be clearly established prior to the use of that
customer s CPNI.
9 RGSI has a supervisory review process regarding compliance with the CPNI rules for
outbound marketing situations and will maintain compliance records for at least one year.
Specifically, RGSI s sales personnel will obtain express approval of any prop osed
outbound m arketing request for customer approval of the use of CPN I by the RGSI s
General Counsel.
10
RGSI no tifies customers imm ediately of any account changes, including address of
record, authentication, online account and password related changes.
11
RGSI may negotiate alternative authentication procedures for services that RGSI
provides to business customers that have a dedicated account representative and a
contract that specifically addresses RGSI s protection of CPNI.
8/9/2019 RGSI 2015 CPNI Certification and Attachment A.pdf
http://slidepdf.com/reader/full/rgsi-2015-cpni-certification-and-attachment-apdf 8/8
12. RGSI is prepared to provide written notice within five (5) business days to the FCC of
any instance where the opt-in mechanisms do not work properly to such a degree that
consumer s inability to opt-in is more than an anomaly.