rgsi 2015 cpni certification and attachment a.pdf

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)



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.



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



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



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



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



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.



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.

rgsi 2015 cpni certification and attachment a.pdf

Documents