protec_mobile_comm_cpni_certification - 2015.doc

7/21/2019 ProTec_Mobile_Comm_CPNI_Certification - 2015.doc

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VIA ELECTRONIC FILING

Marlene H. Dortch, Office of the SecretaryFederal Communications Commission

445 12th Street, SW Suite W!"#25

Washin$ton, D.C. 2%554

&e' Annual 47 C.F.R. § 64.2009(e) CPNI Cert!"at#n

C#$ern% Calen&ar 'ear 20

E* +#",et N#. 06-6

Pr#-Te" /#le C#11un"at#n3 In".

499 Fler I+ 200 5 FRN 000979

C(&)F)C")O*

), Catherine (. Sutter, here+y certify that ) am an officer of the comany named a+o-e,and actin$ as an a$ent of the comany, that ) ha-e ersonal no/led$e that the comany has

esta+lished oeratin$ rocedures effecti-e durin$ the calendar year 2%15 that are ade0uate to

ensure comliance /ith the Customer rorietary *et/or )nformation rules set forth in 4

C.F.&. 33 4.2%%1 et seq. of the rules of the Federal Communications Commission.

"ttached to this certification is an accomanyin$ statement that i6 e7lains ho/ thecomany8s rocedures ensure that the comany is in comliance /ith the re0uirements set forthin 4 C.F.&. 33 4.2%%1 et seq. of the rules, ii6 e7lains any actions taen a$ainst data +roers

durin$ the ast year, iii6 summari9es all customer comlaints recei-ed in the ast year

concernin$ the unauthori9ed release of C*) and i-6 reorts information no/n to the comanyre$ardin$ tactics rete7ters may +e usin$ to attemt access to C*).

he comany reresents and /arrants that the a+o-e certification is consistent /ith 4.

C.F.&. 3 1.1 /hich re0uires truthful and accurate statements to the Commission. he comanyalso acno/led$es that false statements and misreresentations to the Commission are

unisha+le under itle 1: of the ;.S. Code and may su+<ect it to enforcement action.

===============================================

*ame' Catherine (. Sutter itle' resident, ro!ec Mo+ile Communications, )nc.

Date' March 1, 2%1



ro!ec Mo+ile Communications

4>> Filer )D :2%%:: ? F&* %%%15>::>

C*) Certification

S"(M(*

ro!ec Mo+ile Communications @CarrierA6 is n#t nter"#nne"te& t# te Pul" 8t"

Tele#ne Net8#r, (:PTN;)3 and conse0uently does not ha-e the tye of confidential and

rorietary information that the Federal Communication Commission @CommissionA6 customer

rorietary net/or information @C*)A6 re$ulations are desi$ned to rotect.

Carrier offers only t/o!/ay disatch ser-ice, /here communications are +et/een

oerators of mo+iles and orta+les in the field and a disatcher at a console in an office.

Carrier8s facilities are used +y +usiness customers, not +y consumers, and fill a -ery secific,niche communications re0uirement for one!to!many mo+ile transmissions. hey in-ol-e

+usiness, not ersonal, communications and, +y their nature, are far from ri-ate. herefore,

there is little or no lielihood that Carrier /ill e-er ha-e information that re0uires C*) rotection.

*e-ertheless, and out of an a+undance of caution, Carrier has esta+lished the oeratin$ rocedures detailed +elo/ that ensure comliance /ith the Commission8s re$ulations re$ardin$

the rotection of C*)'

• Carrier has adoted a manual and ees it udated /ith FCC C*) rule re-isions, and

has desi$nated a C*) comliance officer to o-ersee C*) trainin$ and imlementation.

• Carrier continually educates and trains its emloyees re$ardin$ the aroriate use of

C*). Carrier has esta+lished discilinary rocedures should an emloyee -iolate theC*) rocedures esta+lished +y Carrier.

• Carrier has imlemented a system /here+y the status of a customer8s C*) aro-al can

+e determined rior to the use of C*).

• Carrier maintains a record of its and its affiliatesB sales and maretin$ camai$ns that use

its customersB C*). Carrier also maintains a record of any and all instances /here C*)/as disclosed or ro-ided to third arties, or /here third arties /ere allo/ed access to

C*). he record includes a descrition of each camai$n, the secific C*) that /as

used in the camai$n, and /hat roducts and ser-ices /ere offered as a art of thecamai$n.

• Carrier has esta+lished a suer-isory re-ie/ rocess re$ardin$ comliance /ith the C*)

rules /ith resect to out+ound maretin$ situations and maintains records of carrier comliance for a minimum eriod of one year. Secifically, Carrier8s sales ersonnel

o+tain suer-isory aro-al of any roosed out+ound maretin$ re0uest for customer

aro-al re$ardin$ its C*), and a rocess ensures that ot!out elections are recordedand follo/ed.

• Carrier has esta+lished rocedures to notify la/ enforcement and customers6 of



ro!ec Mo+ile Communications

4>> Filer )D :2%%:: ? F&* %%%15>::>

C*) Certification

unauthori9ed disclosure of C*) in accordance /ith FCC timelines.

• Carrier too the follo/in$ actions a$ainst data +roers in 2%15, includin$ roceedin$s

instituted or etitions filed +y Carrier at a state commission, in the court system, or at the

Federal Communications Commission' N#ne

• he follo/in$ is information Carrier has /ith resect to the rocesses rete7ters are

usin$ to attemt to access C*), and if any /hat stes carriers are tain$ to rotect

C*)' Carrer a &eter1ne& tat n# rete<ter a atte1te& t# a""e CPNI #n

Carrer= >te1.

• he follo/in$ is a summary of all customer comlaints recei-ed in 2%15 re$ardin$ the

unauthori9ed release of C*)'

o *um+er of customer comlaints Carrier recei-ed in 2%15 related to unauthori9edaccess to C*), or unauthori9ed disclosure of C*)' N#ne

o Cate$ory of comlaint'

0 *um+er of instances of imroer access +y emloyees

0 *um+er of instances of imroer disclosure to indi-iduals not

authori9ed to recei-e the information 0 *um+er of instances of imroer access to online information +y

indi-iduals not authori9ed to -ie/ the information 0 *um+er of other instances of imroer access or disclosure

o Descrition of instances of imroer access or disclosure' N#ne

protec_mobile_comm_cpni_certification - 2015.doc

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