Customer Proprietary Network Information ("CPNI")
What is CPNI?
Who must comply with CPNI safeguard requirements?
What requirements does the FCC impose to ensure the protection of CPNI?
What regulatory filing requirements associated with CPNI?
How can The Commpliance group assist carriers with CPNI compliance?
CPNI, or Customer Proprietary Network Information, is certain customer information that a telecommunications service provider must protect from unauthorized disclosure. Under the FCC’s definition, CPNI includes information relating to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscriber of which the carrier is aware solely by virtue of the carrier-customer relationship. The term includes most information in customer bills, but expressly excludes subscriber list information and aggregate customer data.
Who must comply with CPNI safeguard requirements?
The FCC CPNI rules apply to all telecommunications service providers. This includes landline local and long distance carriers, wireless service providers and interconnected VoIP providers.
What requirements does the FCC impose to ensure the protection of CPNI?
In order to guard against “pre-texting,” the FCC has recently imposed stringent safeguarding requirements on telecommunications service providers. Under the FCC’s CPNI regulations, all service providers must institute employee training programs and supervisory review of all marketing programs which use CPNI. Service providers must also adopt certain CPNI protection mechanisms, including the use of password protection and online customer verification.
In addition, service providers must provide customers with specific notice of their rights to restrict the use of their CPNI. Depending upon the type of marketing campaign, carriers must either receive opt-out or affirmative opt-in consent for the disclosure of customer CPNI to certain third parties. The FCC requires carriers to notify law enforcement and individual customers of security breaches involving CPNI.
What regulatory filing requirements associated with CPNI?
The FCC requires that all service providers file an annual CPNI certification with the Commission. This CPNI certification must provide a detailed outline of the steps a service providers has taken to guard against unauthorized access to CPNI. Providers must keep this annual certification on file and make this certificate available for public inspection.
All service providers should be aware that filing CPNI certifications is another regulatory area where full compliance is absolutely necessary. Fines for failure to comply with CPNI rules can be substantial. Under the rules, the FCC is authorized to impose fines of up to $130,000 for each rule violation or each day of a continuing violation up to a maximum of $1.3M for each continuing violation.
How can the Commpliance Group assist carriers with CPNI compliance?
The CommLaw Group’s federal regulatory experience can help service providers guarantee that they achieve full compliance with the all of the FCC’s CPNI regulations. We have helped numerous VoIP providers, wireless and wireline carriers meet their CPNI compliance obligations.
- Obtaining a 214 License
- Registering with the FCC
- Customer Proprietary Network Information ("CPNI")
- Interconnected VoIP
- Universal Service Contribution
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