This is a reminder that all telecommunications and interconnected VoIP providers must file an annual Customer Proprietary Network Information (“CPNI”) report for calendar year 2017 by March 1, 2018. The CPNI reports certify that telecommunications providers are in compliance with the Commission’s CPNI rules. As a reminder, these reports were not required last year, but due to the rescind of the Privacy Order, the Commission again requires this filing for 2018.

The Wireline Bureau released a Public Notice detailing the required information, which contains Frequently Asked Questions, a draft CPNI certification template, and the full text of the CPNI rules. These documents may assist with the completion of the CPNI report and may be helpful to review.

The FCC’s CPNI rules protect the security of personal data that consumers disclose to their service providers as a result of their business relationships. The rules require telecommunications providers to establish and maintain systems that protect this CPNI. The rules also require providers to file an annual certification that documents (1) their compliance with the rules, (2) complaints they received from consumers regarding CPNI, and (3) actions they took against data brokers. The FCC intends to strictly enforce its CPNI rules, and if a telecommunications provider fails to comply with the rules or the certification requirement, then the Commission may impose a forfeiture of up to $196,387 for each violation, or each day of a continuing violation, up to a maximum fine of $1,963,870.

You can file your certification online via the ECFS portal, under EB Docket No. 06-36. Filings must include the certification required under 47 CFR 64.2009(e) (using the FCC’s template), and a written statement explaining how the company’s operating procedures ensure that it is or is not in compliance with the CPNI rules with a signed compliance certificate. If applicable, companies should also include an explanation of actions taken against data brokers and/or a summary of customer complaints.

Please Contact Us if you have any questions.