You are on page 1of 2


Keystone Broadband, LLC.

Keystone Broadband, LLC. (“Keystone”) has established and implemented internal operating
procedures which are designed to ensure compliance with the requirements of Section 222 of the
Communications Act of 1934, as amended, (Privacy of Customer Information) and with the Federal
Communications Commission's rules governing Customer Proprietary Network Information (CPNI)
which are codified at 47 C.F.R. Part 64, Subpart U.
Primary responsibility for Keystone's CPNI practices and policies resides with the company's
President. This corporate officer has reviewed Section 222 and the FCC's CPNI rules and is
thoroughly familiar with their requirements.
Keystone does not make available to any affiliated or unaffiliated entity information which meets
the definition of CPNI codified at 47 U.S.C. § 222(h)(l), except when required to do so by law (e.g.,
when subject to a subpoena, search warrant, court order). Consistent with the Commission's rules,
Keystone's policies provide for the use of CPNI without customer approval for the purpose of providing
or marketing service offerings among the category of services to which the customer already subscribes
from Keystone.
Keystone has implemented an “opt-out” approval procedure in compliance with 47 C.F.R. §
64.2007 of the Commission's rules. All current and new customers receive written notification of the
customer's right to restrict use of, disclosure of, and access to that customer's CPNI, in conformity with 47
C.F.R. § 64.2008(c) of the Commission's rules. Record is kept of all customers who have notified Keystone
that they wish to “opt-out” of marketing service offerings that are within a category of service to which the
subscriber does not already subscribe from Keystone. All “opt out” customers are excluded from any and
all marketing communications for telecommunication service offerings that are within a category of service
to which the subscriber does not already subscribe from Keystone.
In accordance with 47 C.F.R. § 64.2009(c), Keystone maintains records of all sales and marketing
campaigns conducted by Keystone or a third party acting on behalf of Keystone that use customers' CPNI
data. As required by Section 64.2009(c), Keystone's records include a description of the campaign, the
specific CPNI that was used in the campaign, and what products and services were offered as part of the
campaign. Keystone retains these records for more than the minimum required one year. In accordance
with Section 64.2009(d), Keystone has an established supervisory review process regarding compliance
with the rules for outbound marketing situations and maintains records of Keystone's compliance for
more than the minimum required period of one year.
Keystone will disclose to a customer that customer's own CPNI information after properly
authenticating the customer as required by the FCC's rules and regulations. It will also disclose CPNI
information to a person specifically designated by an authenticated customer such as, for example, an
attorney who represents the customer in a matter where the CPNI information is necessary to the
attorney's effective representation of the customer, but only upon receiving a direct request in writing
from the customer.
All Keystone personnel having access to CPNI have been instructed as to Keystone's policies
Keystone Broadband, LLC CPNI Statement of Compliance Procedures
Filer ID 829656

Page 1 of 2

governing CPNI. Keystone has internal procedures in place to educate its employees about CPNI and the
disclosure of CPNI. Keystone employees that have access to this information are aware of the FCC’s rules
and are prohibited from disclosing or permitting access to CPNI without the appropriate customer consent
or as allowed by law and the FCC rules. Any employee that discloses CPNI in violation of these procedures
is subject to disciplinary action, and possible termination.
Keystone has not taken any action against data brokers during the preceding year regarding
unauthorized release of CPNI; nor has Keystone received any customer complaints concerning the
unauthorized access to or unauthorized disclosure of CPNI. Keystone has implemented safeguard
procedures to protect our customers’ CPNI from pretexters including, but not limited to, the adoption and
implementation of a policy for customer requests for CPNI consistent with 47 C.F.R. §64.2010.
These procedures and policies have been specifically approved by Keystone's corporate officers.

Keystone Broadband, LLC CPNI Statement of Compliance Procedures
Filer ID 829656

Page 2 of 2