Vanco Solutions 2015 CPNI Certification and Attachment A.pdf
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8/9/2019 Vanco Solutions 2015 CPNI Certification and Attachment A.pdf
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TAI LAW GROUP PLLC
Christopher C. Tai 1330 Connecticut Avenue, NW
chris@tailawgroup.com 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: Vanco Solutions, 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
Vanco Solutions, Inc. (“Vanco”) and signed by Vanco’s President.
Should you have any questions, please do not hesitate to contact the undersigned.
Respectfully submitted,
/s/
_______________________________
Christopher C. TaiColleen A. Sechrest
Counsel for Vanco Solutions, Inc.
Enclosure as stated
cc: Best Copy and Printing, Inc. (one copy via email)
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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: Vanco Solutions, Inc.
Form 499 Filer ID: 828618
Name of signatory: Janet Troxell
Title of signatory: President
I, Janet Troxell, certify that I am President of Vanco Solutions, Inc. ( Vanco )
and, acting as an agent of Vanco, that I have personal knowledge that the company has
established operating procedures (described in Attachment A) that are adequate to ensure that
Vanco is in compliance with the Commission's CPNI rules.
See
47 C.F.R. § 64.2001
et seq
Attached to this certification is an accompany ing statement explaining how
Vanco's procedures ensure that Vanco 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.
Vanco has not taken any actions
i.e.
proceedings instituted or petitions filed at
either state commissions, the court system, or at the Commission against data brokers) against
data brokers in the past year.
8/9/2019 Vanco Solutions 2015 CPNI Certification and Attachment A.pdf
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a
nco ha
s not re
ceived
anycu
stomer
compl
aints in
thepa
st year
concer
ning th
e
unautho
rized re
lease of
CPNI.
Van
co repre
sents an
d warr
ants tha
t the ab
ove cert
ificatio
n is con
sistent w
ith 47
C.F.R.
§
1.17 w
hich re
quires t
ruthful
and acc
urate st
atement
s to the
Com m
ission. T
he com
pany a
lso
acknow
ledges
that fa
lse state
ments a
nd misr
epresen
tations
to the C
ommis
sion are
punish
able
un
der Title
18 of t
he U.S.
Code an
d may s
ubject i
t to enfo
rcemen
t action.
.-..f m it
l
Jan
et
ell P
resi ent
net
V
anco So
lutions
Inc.
Date
:
. - W
2
015
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TT CHMENT
ST TEMENT OF CPNI COMPLI NCE PROCEDURES
1
It is Vanco Solutions, Inc. ( Vanco ) policy not to use CPNI for any activity other than
permitted by law. A ny disclosure of CPNI to other parties (such as affiliates, vendors
and agents) occurs only if it is necessary to conduct a legitimate business activity related
to the services already provided by Vanco to the custom er. If Vanco is not required by
law to disclose the CPNI or if the intended use does not fall within one of the regulatory
carve-outs, Vanco will first obtain the customer's consent prior to using CPNI.
2
Vanco follows industry-standard practices to prevent unauthorized access to CPNI by a
person other than the subscriber or Vanco. However, Vanco cannot guarantee that these
practices will prevent every unauthorized attempt to access, use or disclose personally
identifiable information. Therefore:
a If an unauthorized disclosure occurs, Vanco shall provide notification of the
breach within seven (7) days to the United States Secret Service and the Federal
Bureau of Investigation.
b
Vanco shall wait an additional seven (7) days from its government notice prior to
notifying the affected customers of the breach.
c
Notwithstanding the provisions in subparagraph (b) above, Vanco shall not wait
the additional seven (7) days to notify its customers if Vanco determines there is
an immediate risk of irreparable harm to the customers.
d
Vanco shall maintain records of discovered breaches for a period of at least two
(2) years.
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3
ll employees will be trained as to when they are, and are not, authorized to use CPNI
upon employment with Vanco and annually thereafter.
a. Specifically, Vanco 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 Vanco calls the customer s telephone number of record and
discusses the information with the party initially identified by customer
when service was initiated
b. Vanco 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
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vi
. To market ad
ditional service
s to customers
with the recei
pt of informed
conse
nt via the use of
opt-in or opt-o
ut elections as
applicable.
4 Prior to
allowing acce
ss to customer
s individually
identifiable CP
NI to Vanco s
joint
venturers or
independent c
ontractors, Va
nco will requi
re, in order to s
afeguard that
information,
their entry into
both confidenti
ality agreement
s that ensure co
mpliance with
this St
atement and sh
all obtain opt-i
n consent from
a customer pr
ior to disclosin
g the
informa
tion. In additio
n, Vanco requi
res all outside
dealers and age
nts to acknowl
edge
and
certify that they
may only use
CPNI for the pu
rpose for whic
h that informat
ion has
be
en provided
5 Vanco
requires expres
s written autho
rization from th
e customer prio
r to disclosing C
PNI
to new carrier
s except as oth
erwise required
by law.
6 Vanco doe
s not market sh
are or otherwise
sell CPNI to a
ny third party.
7
Van
co maintains a r
ecord of its ow
n and its affiliat
es sales and ma
rketing campai
gns that
use Vanco s c
ustomers CPN
I. The record w
ill include a de
scription of ea
ch campaign,
the specific C
PNI that was u
sed in the camp
aign and what products and services were
offere
d as part of the
campaign
a. Prior to c
ommencemen
t of a sales or
marketing cam
paign that util
izes CPNI,
Vanco e
stablishes the s
tatus of a custo
mer s CPNI app
roval. The foll
owing sets
forth the pro
cedure followed
by Vanco
i. Prior to any
solicitation f
or customer a
pproval, Van
co will notify
customers of their right to restrict the use of, disclosure of, and access to
their C
PNI
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ii. Vanco will use opt-in approval for any instance in which Vanco 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
Vanco provides individual notice to customers when soliciting approval to
use, disclose, or permit access to CPNI.
vi.
The content of Vanco s CPNI notices comply with FCC rule 64.2008(c).
8
Vanco has im plemented 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
Vanco 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, Vanco s sales personnel will obtain express approval of any proposed
outbound marketing request for customer approval of the use of CPNI by the Vanco s
General Counsel.
10 Vanco
notifies customers immediately of any account changes, including address of
record, authentication, online account and password related changes.
11
Vanco m ay negotiate alternative authentication procedures for services that Vanco
provides to business custom ers that have a dedicated account representative and a
contract that specifically addresses Vanco s protection of CPNI.
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12. V
anco is
prepare
d to pro
vide wr
itten no
tice wit
hin five
(5) bus
iness da
ys to th
e FCC
of
any
instance
where
the opt
-in mec
hanism
s do no
t work p
roperly
to such
a degr
ee that
c
onsume
r s inab
ility to o
pt-in is
m ore th
an an a
nomaly
.
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