1. 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
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2. 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.
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3. 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.
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4. 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
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5. “PI” Defined Examples of PI:
First name (or first initial) and last name
Home or other physical address
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
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6. 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.
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7. 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
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8. 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
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9. 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)
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10. 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
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11. 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
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12. 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
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13. 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
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14. CPNI Authentication Methods:
4. Photo ID
Customers may use a valid photo ID to access their account when requesting information in person
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15. 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
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16. 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
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17. CPNI & PI Email Limitations
Employees should not send s containing CPNI & PI externally.
CPNI and PI can only be sent via if the is transmitted internally over Hamilton’s own network (to a Hamilton address) as long as there is no data for multiple customers.
Sending s 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.
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18. Thank You
If you have any questions, feel free to contact your Supervisor or:
Beth Slough Kiley James
Phone: Phone:
REMEMBER to take the Quiz to satisfy the Annual CPNI Training required by the FCC
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