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Buggs Island Telephone Cooperative BIT Communications

EB Docket 06-36 Annual64.2009(e) CPNICertification 20l l for Datesigned: February 2012 23, Names Company of Covered this Certification: by BuggsIslandTelephone Cooperative Nameof signatory: MickeyL. Sims Title of signatory: General Manager I, Mickey L. Sims,certifuthat I am an officer of the company named above,andactingasan agentof the company, I havepersonal that knowledge the company established that has procedurls operating that are adequate ensure to compliance theCommission's with CPNIrules. 47 C,F.R.g ei.ZOO1 s"q. See et Attached this certification an accompanying to is statement explaining how the company's procedures ensrrethatthe company in compliance is with the requirements (includingthosemanOating adoption the of CPNIprocedures, training,recordkeeping, supervisory and review)setforth in section64.t001et siq. of theCommission's rules. Thecompany not takenactions has (l.e.,proceedings instituted petitionsfiled by a company either or at statecommissions, courtsystem, at the Commission the or against databrokers)against dita brokersin the pastyear.[NOTE:If you reply in the affirmative, please providean explanation anyactions of taken against databrokers,] Thecompany not received has customer complaints the pastyearconcerning unauthorized in the release of CPNI [NOTE:If you reply in the affirmative, please providea summary suchcomplaints. of This summary shouldincludenumberof complaints, brokendownby category complaint, or e.g.,instances improper of access employees, by instances improper of disclosure individuals authoriied receive to not to the information, instances improper or of access onlineinformation individuals authorized view the to by not to information.l Thecompany represents warantsthattheabove and certification consistent 47. C.F.R.S 1.17which is with requires truthful andaccurate statements the Commission. company to The alsoacknowledges false ihat statements misrepresentations Commission punishable and to the are underTitle l8 of theU.S.Codeand may subject to enforcement it action. 499FilerID 801l2 3

100 Nellie Road . Jones

. 129 , Bracey,Virginia 23919. Phone (434)636-2274 Fax(494)O3O-1211

Toll Free, 888-829-2844 . www.bitbroadband.com

BUGGSISLAND TELEPHONE COOPERATIVE
100 Nellie Jones Road p.O. Box 129"Bracey. VAZJIL} 499 Filer ID 801312 2011 ANNUAL STATEMENT OF FCC CPNI RULE COMPLIANCE f,'ebruary 3,2012 This statement serves explainhow BuggsIslandTelephone to Cooperative ("Company")is complyingwith FederalCommunications Commission ("FCC") rulesrelatedto the privacy of cuitomerinformation. The type of information which customer for privacy is protected the FCC's rules is called,,customer by proprietary networkinformation"("CPNI"). The FCC's rulesrestricting telecommunication company use of GPNIarecontained atPart64, Subpart of theFCC'srules(47 c.F.R. $$ 64.2000-2011). U All subsequent references rule sectionsrefer to rules under Part 64, Subpart IJ unlessotherwise to indicated. l. Uses CPNI for Marketing of The Company limits useof CPNI for marketing the following: to Pursuant sections64.2007(a)and 64.2008(f),the company usescpNI, subjectto to customer authorization, one-time duringin-boundcallsfrom customers, for use Pursuant to Section 64.2005(a),the company uses cpNI from a category of telecommunications service(local, interexchange wireless)for marketingtimitiO to or use for marketingservicesin the samecategoryof servicefrom which the CPNI is derivedor to another category telecommunications of serviceto which the customer also subscribes. 2, Identification CPNI of The Companyhas established procedures and trained employees having access or occasionto use to, customer data, identiff what customer to informationis CPNI consistent with the definitionof CpNI under the Sgction 64.2003(9) Section and 222(t)(l) of the Communications of 1934 amended U.S,C.$ Act (47 as 222(t)(1)). 3. Identification Services of Affectedby CpNI Rules The Companyhas established procedures and trained employees recognizethe different types of to telecommunications non-telecommunications and services affecthow the Company that usesCpNI. 4. Identification Permissible of Uses CPNI without Customer of Authorization TheCompany established has procedures trainedemployees and havingaccess or occasion useCpNI, to, to to identifiz usesof CPNI not requiringcustomer authorization underSection64.2005. 5. Identification Uses CPNI RequiringCustomer of of Authorization TheCompany established has procedures trainedemployees and havingaccess or occasion useCpNI, to, to to identi$rusesof GPNIrequiringcustomer authorization underSection64.2007. 6. Customer One-TimeNotificationand Authorizationprocess The Company developed has procedures one-time for oral notificationof customers makingin-boundcalls regarding CPNI pursuant the requirements Section64.2007generallyand Section64.2007generally to of andSection (D 64.2007 specifi cally. 7. Recordof Customer CPNI Approval/Non-Approval At suchtime as Company may initiateuseof CPNI for outbound marketingof services outsidea category currentlyprovidedto a customer, with corresponding launchof a notificationand Opt-Outprocess, the

BuggsIslandTelephone Cooperative

Company will develop utilize a system maintaining and for readilyaccessible recordof whetherandhow a customer responded opt-out approval required Section64.2009(a). has to as by 8. Procedures Protecting AgainstDisclosure CpNI of The Companyin placeprocedures compliance for with Section64.2010 including,but not limited to the following:* proceduresfor authentication customersbefore disclosing CPNI on customer-initiated of telephone contacts business or office visits; procedures provideimmediate to notificationto customers account of changes, includingchanges in address-of-record attemptsat access CPNI through use of back-upmethodsdue to and to forgotten passwords. *The companydoesnot provideon-lineaccess to customer account information. 9. ActionsTakenAgainstData Brokersand Responses CustomerComplaints to Pursuant Section to 64.2009, Company the makes following explanation any aitions takenagainst the of databrokersanda summary all customer of complaints received the pastyearconcerning in the unauthoriz;ed release CPNI: of Not apnlicable, No actions takenagainst data-brokers. No customer complaints received. 10. Disciplinary Process The Company in placean express has disciplinary process address unauthorized of CpNI where to any use the circumstances indicate authorization required is undersection64.2009(b). ll. Supervisory Review Process Outbound for Marketing The Company has a supervisory review process ensure to compliance with Section64.2009(d) the of FCC'sPart64, Subpart CPNI rulesaswell asrelated U pursuant Section64.2009(c). record-keeping to 12, Procedures NotifyingLaw Enforcement cpNI security Breaches for of The companyhas adopted procedures comply with Section64.20rl for notif,iing law enforcement to of CPNI security breaches, together with related record-keeping deferred and notificationto customers.