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2011 CPNI Questionnaire for BVU

2011 CPNI Questionnaire for BVU

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Published by fcc_filings
FCC CPNI Submission
FCC CPNI Submission

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Published by: fcc_filings on Feb 20, 2012
Copyright:Attribution Non-commercial


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2011 CPNI Questionnaire For BVUAI.Use of CPNI for Marketing
1)Do you useCPNIto market any telecommunications or non-telecommunications services, either through your own sales force or through agents or other third parties?Yes No
 If response to Question 1 is NO, skip to question 8.
2)Do you use CPNI ONLY for one or more of the following purposes (SeeSection II of CPNI Summary):a)to market service offerings that are within the same category of service that you already provide to the customer (i.e., "total service approach"—seeSection IIAof CPNISummary)? b)to provide your customer with customer premises equipment, call answering, voice mailor messaging, voice storage or retrieval, fax store and forward, and protocol conversion?c)to provide inside wire installation, maintenance and repair services?d)for local carriers, to market features such as speed dialing, computer provided DirectoryAssistance, call tracing, call blocking, call return, repeat dialing, call tracking, callwaiting, caller ID, call forwarding and certain centrex features?e)to protect your Company's rights or property?f)to protect your customers and other carriers from fraudulent, abusive or unlawful use or subscription of service?g)For CMRS providers only:i) in conjunction with research on the health effects or CMRS.ii)for the provision of CPE and information services.Yes No
 If the response to Question 2 is YES, no customer approval or notification is required -- skip toQuestion 5.
3)If you use CPNI for purposes other than those listed in Question 2, customer approval is required —please respond to the following questions:a)Explain your procedures for notifying customers of their right to restrict use of,disclosure, and access to their CPNI, prior to asking for approval to use CPNI. (SeeSection V.B. of CPNI Summary for notification requirements.)If you use opt-out approval, do you provide notice to customers every two years?Yes No b)Describe the procedures that you use for obtaining customer approval, establishing proof that approval was obtained, and maintaining records of customer approval. For instance,do you rely on opt-in approval (where the customer affirmatively agrees to the use of their CPNI), or Opt-Out approval (where the customer is required to notify you if theyDO NOT want you to use their CPNI); do you rely on oral, written, and/or electronicmethods of approval. (SeeSection V.of CPNI Summary)
4)If you use CPNI in a manner requiring customer approval, do you have a system that indicates thestatus of the customer's CPNI approval (e.g., a flag in the customer service record)? (SeeSectionVI.A of CPNI summary)Yes No
5)Do you train your personnel as to when they are and are not authorized to use CPNI and have adisciplinary process in place? (SeeSection VI. E of CPNI summary) Yes NoBriefly describe.BVUA has a CPNI manual that covers disciplinary action and as part of the CPNI
employees sign a doument that acknowledges potential disciplinary action. For example anexerpt states, "
Violation by Company employees and agents of such CPNI requirementswill lead to prompt disciplinary action (up to and including remedial training, reprimands,unfavorable performance reviews, probation, and termination), depending upon thecircumstances of the violation (including the severity of the violation, whether the violationwas a first time or repeat violation, whether appropriate guidance was sought or receivedfrom the CPNI Compliance Officer(s), and the extent to which the violation was or was notdeliberate or malicious).
6)Do you maintain a record of your company's and any affiliate's sales and marketing campaignsthat use CPNI? (SeeSection VI.Cof CPNI summary)Yes No7)Do you have a supervisory review process for compliance with CPNI rules for outboundmarketing situations to ensure that sales personnel obtain supervisory approval of any proposedoutbound marketing request for customer CPNI approval? (SeeSection VI.D and Eof CPNIsummary)Yes NoBriefly describe the process and recordkeeping.All outbound marketing situations must be approved by the Compliance Officer and after approval the effort is documented. The Compliance Officer will maintain a record of each out- bound marketing activity or campaign, including:a. a description of the campaign;b. the specific CPNI that was used in the campaign;c. the date and purpose of the campaign:d. the name and relationship of any third party to which CPNI was disclosed or provided, or which was allowed to access CPNI; ande. what products and services were offered as part of the campaign.

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