Professional Documents
Culture Documents
Annual 64.2009(i)
Cfm
Ip: 00ll-4377-46
l
of
Attached to this certification is an accompanying sta{ement explaining how the company's procedures
ensure that the c{mpany is in compliance with the requiremefts set forth in section 64.2001 et seq. of the
Commission's nlles.
The comsany has not taken any actions (proceedings instituted or petitions filed by a company at either
state commissiorfs, the court system, or at the Commission a$ainst data brokers) against data brokers in the past
year. Companie$ must rcport on any information that they h{ve with respect to the processes pretexters are using to
attempt to accesl CPNI , and what steps companies are takin$ to protect CPNI.
Th" con:jpany has not received any customer complaids in the past year concerning the unauthorized
release of CPNI {number ofcustomer complaints a company has received related to unauthorized access to CPNI,
or unauthorized {isclosure of CPNI, broken down by categorf or complain! e.g., instances of improper access by
employees, instafrces of improper disclosure to individuals n{t authorized to receive the information, or instances of
improper access [o online information by individuals not aut4orized to view the information).
Signed
February 10,2015
TO: Marlene H. portch, Office of the Secretary
Federal Con[munications Commission
445 l2th Strqet SW
Washingtonl DC 20554
Pursuant fo the Federal Comrnunications Commission ("Qommission") pursuant to section 222 of the
Comrnunfcations Act of 1934, as amended ("the Act,,), 4Z U.S.C.g222 and the Commission,s rules, 47 C.F.R.
$64.2001i e/ seq., as amended rule 47 C.F.R. 964.2009(e)
frovide annual certification to the Commission.
ftovide explanation of any actions taken against pata brokers in the past year,
frovide a summary of all customer complaints riceived in the past year conceming tle unauthorLed
a.
b.
c.
2.
3.
4.
4elease
of CPNI.
To prote(t customer proprietary network information 1"C{Nf1, COES felecom has had in place and continues to
provide cfrstomer safeguards and appropriate security mealsures in accordance with CPM rules since its fust resale of
a LEC se{vices and customer billing in the fourth quaxter gf2005, and continues to do so as a fimdamental business
principal.]GOES Telecom did make a CPNI filing (with ofly one customer on the books) on February 3, 2006 in
accordanfe with FCC 47 C.F.R. par. 64.2009(e) FCC confirrnation number 200623060361, Docker: 06-36.
From 20Q3, the formation ofGOES Telecom (November 17, 2003, certificate of incorporation previously filed),
through tfe fourth quarter of2005 and the acquisition offw first customer, we were in the startup phase ofthe
business fleveloping and implementing safeguards to protEct customer proprietary network information, obtaining
New JersFy Board ofPublic Utilities approval, interconnei:tion agreements, FRN, and implementing CPNI
(previousfly filed documents). We believe that we have bein aad continue to be in compliance with CPNI rules, from
the first dpy of our first customer acquisition. GOES Teleciom Annual Compliance Certificate and certification are
enclosed.r
GOES t{lecom has previously provided its Corporate Tralining Manual, which covers protections of CPNI data
includingipretexting. Additional tracking forms to maintaiir CPNI compliance under 47 C.F.R. $64.2009(e) are
attachedi
All
l.l6
as set
forth therein.
Norman Brandinlger,
GOES Telecom,llnc.
Encl.