2016 Annual CPNI Training CPNI & PI Awareness Beth Slough, Director of Account Management/Relay Compliance Manager Kiley James, NSC Director of Marketing and Customer Service Proprietary and Confidential Information of

CPNI Defined Customer Proprietary Network Information (CPNI) is broadly defined as: Information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer of TRS or telecommunications service provider, and that is made available to the TRS or telecommunications service provider by the customer solely by virtue of the carrier-customer relationship. CPNI is information that companies have available to them because of the relationships they have with their customers. Proprietary and Confidential Information of

CPNI Defined Examples of CPNI are: To whom, where and when a customer places a call Length of and toll amount of a call Service offerings Customer’s account or profile information Calling features and technical configurations to which the customer subscribes CPNI also includes information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of a carrier; except that such term does not include subscriber list information. Proprietary and Confidential Information of

Personally Identifiable Information (PI) Defined Personally Identifiable Information (PI) is defined as: Customer information, such as personal data, beyond CPNI, that customers expect their carriers to keep private Proprietary and Confidential Information of

“PI” Defined Examples of PI: First name (or first initial) and last name Home or other physical address Email address, user name, or other online contact information Telephone number CapTel Electronic Serial Number SSN or other government-issued unique identification number Account numbers, credit or debit card numbers, and any information combined that would allow access to a consumer’s accounts URL, Internet Protocol address, or host name that identifies an individual A customer’s doctor’s name, doctor’s contact information, or any other health-related information Hamilton may collect or obtain Any combination of the above Proprietary and Confidential Information of

Compliance Requirements General Duty: Every employee has the duty to protect the confidentiality of proprietary information (including CPNI and PI) of all customers. This includes any such information regarding customers of other telecommunications carriers or companies which Hamilton may receive or have in its possession. Proprietary and Confidential Information of

Company Focus on CPNI & PI Why It Matters Company Focus on CPNI & PI Protecting our customers’ privacy and keeping the trust of our customers Protecting our customers’ information from getting into hands of third parties without their permission Ensuring that we have proper authorization to change any customer services Proprietary and Confidential Information of

FCC has authority to issue fines: Consequences FCC has authority to issue fines: $4K for not responding $100K for failing to comply $130K per infraction Fines are issued regardless of infraction “Size matters not” Small provider fined the same as a larger provider, such as AT&T or Sprint Proprietary and Confidential Information of

CPNI Authentication Authentication means confirming that the person requesting CPNI data has the authority to receive that information All Hamilton companies have procedures in place to ensure authentication for release of customer account or profile data Such procedures include: Password/PIN Calling the telephone number on record Alternate profile or account information Valid Photo ID (in-office visit only) Proprietary and Confidential Information of

CPNI Authentication cont. Examples of when authentication is required: Customer calls to update information on profile/account Customer attempts to set up profile or add a service to account on an existing profile/account Customer requests forgotten username and/or password/PIN Follow up with a customer in regards to technical or billing issue Proprietary and Confidential Information of

CPNI Authentication Methods: 1. Password / PIN Hamilton does not assign Passwords/PINs - it is up to the customer to create them Customer must be authenticated in order to change a password or PIN associated with an account Proprietary and Confidential Information of

CPNI Authentication Methods: 2. Calling the telephone number on record The customer must be called at the phone number listed on profile or account Caller ID is not a valid method of authentication Proprietary and Confidential Information of

CPNI Authentication Methods: 3. Alternate Information Listed Customers may use other information listed on their profile or their account as a method of authentication The information must be a specific to information contained in the profile/account and not publicly accessible information such as an address Proprietary and Confidential Information of

CPNI Authentication Methods: 4. Photo ID Customers may use a valid photo ID to access their account when requesting information in person Proprietary and Confidential Information of

When in doubt, contact a customer care representative CPNI Authentication Conclusion How does authentication apply to me? Are you being asked to provide information specifically listed in a customer’s account? Remember you must authenticate using approved methods before providing such information When in doubt, contact a customer care representative Proprietary and Confidential Information of

CPNI for Marketing Purposes The FCC has specific and detailed rules regarding the use of CPNI for marketing purposes In some cases, customer approval is required and may be obtained through an opt-in/opt-out method Please contact a marketing representative before using CPNI for marketing purposes Proprietary and Confidential Information of

CPNI & PI Email Limitations Employees should not send emails containing CPNI & PI externally. CPNI and PI can only be sent via email if the email is transmitted internally over Hamilton’s own network (to a Hamilton email address) as long as there is no data for multiple customers. Sending emails with multiple items or lists of CPNI or PI internally or externally is not permitted. If there is a need to send CPNI & PI externally OR a list containing multiple items, contact Corporate IT to discuss a secure solution. Proprietary and Confidential Information of

Thank You If you have any questions, feel free to contact your Supervisor or: Beth Slough Kiley James Phone: 402-694-5101 Phone: 402-694-5101 Beth.Slough@HamiltonRelay.com Kiley.James@HamiltonTel.com REMEMBER to take the Quiz to satisfy the Annual CPNI Training required by the FCC Proprietary and Confidential Information of