January 23, 2007
By Vic Jackson, Interconnection Services, Inc.
Reminder that Customer Proprietary Network Information (CPNI) Compliance Certifications from all Telecommunications Carriers are due by February 6, 2007.
Background:
Early last year (2006) there was some considerable controversy over the disclosure to unauthorized persons, by some cellular carriers, of the confidential cellular telephone records of high profile individuals, especially detailed records of individual calls. The FCC came under intense pressure to stop this unlawful practice by some businesses that were openly advertising their ability to obtain confidential telephone records for a fee, even though there are specific FCC rules against such practices. In response, the FCC ordered all telecommunications carriers to submit a CPNI "Compliance Certification." This "certification" put the onus on high level company officials to make sure the carriers are complying with FCC rules regarding proprietary customer information such as call records.
On January 30, 2006 the FCC’s Enforcement Bureau directed all Telecommunications Carriers to submit Customer Proprietary Network Information (CPNI) Compliance Certifications no later than February 6, 2006. (FCC DA 06-233, Released January 30, 2006.)
Most telecommunications carriers, including paging carriers submitted the CPNI certifications last February 6. Now, because of the FCC requirement for annual certification, new filings are due by February 6, 2007. For paging carriers, CPNI is a relatively benign problem, but a failure to file this FCC required certification could result in some severe penalties.
Listed below is a copy of 47 CFR 64.2009 and the CPNI filing requirement.
TITLE 47—TELECOMMUNICATION, CHAPTER I--FEDERAL COMMUNICATIONS COMMISSION, PART 64_MISCELLANEOUS RULES RELATING TO COMMON CARRIERS, Subpart U_Customer Proprietary Network Information, Sec. 64.2009, Safeguards required for use of customer proprietary network information.
47CFR64.2009
(e) A telecommunications carrier must have an officer, as an agent of the carrier, sign a compliance certificate on an annual basis stating that the officer has personal knowledge that the company has established operating procedures that are adequate to ensure compliance with the rules in this subpart. The carrier must provide a statement accompanying the certificate explaining how its operating procedures ensure that it is or is not in compliance with the rules in this subpart.