Vanco Solutions 2015 CPNI Certification and Attachment A.pdf

8/9/2019 Vanco Solutions 2015 CPNI Certification and Attachment A.pdf

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TAI LAW GROUP PLLC

Christopher C. Tai 1330 Connecticut Avenue, NW

[email protected] Washington, D.C. 20036

Tel. 202.480.9810

February 21, 2015

Marlene H. Dortch

Office of the SecretaryFederal Communications Commission

445 12th

Street, SWSuite TW-A325

Washington, DC 20554

Re: Vanco Solutions, Inc. CPNI CertificationEB Docket No. 06-36

Dear Ms. Dortch:

As required under Section 64.2009(e) of the Commission’s Rules, 47 C.F.R. § 64.2009(e)

and Public Notice DA 15-178 please find enclosed a certificate of compliance with the

Commission’s Customer Proprietary Network Information regulations submitted on behalf of

Vanco Solutions, Inc. (“Vanco”) and signed by Vanco’s President.

Should you have any questions, please do not hesitate to contact the undersigned.

Respectfully submitted,

/s/

_______________________________

Christopher C. TaiColleen A. Sechrest

Counsel for Vanco Solutions, Inc.

Enclosure as stated

cc: Best Copy and Printing, Inc. (one copy via email)


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Annual 47 C.F.R. 64.2009(e) CPNI Certificate

EB Docket No. 06-36

Annual 64.2009(e) CPNI Certification for 2015 covering the prior calendar year 2014

Date filed: February 21, 2015

Name of company covered by this certification: Vanco Solutions, Inc.

Form 499 Filer ID: 828618

Name of signatory: Janet Troxell

Title of signatory: President

I, Janet Troxell, certify that I am President of Vanco Solutions, Inc. ( Vanco )

and, acting as an agent of Vanco, that I have personal knowledge that the company has

established operating procedures (described in Attachment A) that are adequate to ensure that

Vanco is in compliance with the Commission's CPNI rules.

See

47 C.F.R. § 64.2001

et seq

Attached to this certification is an accompany ing statement explaining how

Vanco's procedures ensure that Vanco is in compliance with the requirements (including those

mandating the adoption of CPNI procedures, training, recordkeeping, and supervisory review)

set forth in Section 64.2001 et seq

of the Commission's rules.

See

Attachment A.

Vanco has not taken any actions

i.e.

proceedings instituted or petitions filed at

either state commissions, the court system, or at the Commission against data brokers) against

data brokers in the past year.


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a

nco ha

s not re

ceived

anycu

stomer

compl

aints in

thepa

st year

concer

ning th

e

unautho

rized re

lease of

CPNI.

Van

co repre

sents an

d warr

ants tha

t the ab

ove cert

ificatio

n is con

sistent w

ith 47

C.F.R.

§

1.17 w

hich re

quires t

ruthful

and acc

urate st

atement

s to the

Com m

ission. T

he com

pany a

lso

acknow

ledges

that fa

lse state

ments a

nd misr

epresen

tations

to the C

ommis

sion are

punish

able

un

der Title

18 of t

he U.S.

Code an

d may s

ubject i

t to enfo

rcemen

t action.

.-..f m it

l

Jan

et

ell P

resi ent

net

V

anco So

lutions

Inc.

Date

:

. - W

2

015


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TT CHMENT

ST TEMENT OF CPNI COMPLI NCE PROCEDURES

1

It is Vanco Solutions, Inc. ( Vanco ) policy not to use CPNI for any activity other than

permitted by law. A ny disclosure of CPNI to other parties (such as affiliates, vendors

and agents) occurs only if it is necessary to conduct a legitimate business activity related

to the services already provided by Vanco to the custom er. If Vanco is not required by

law to disclose the CPNI or if the intended use does not fall within one of the regulatory

carve-outs, Vanco will first obtain the customer's consent prior to using CPNI.

2

Vanco follows industry-standard practices to prevent unauthorized access to CPNI by a

person other than the subscriber or Vanco. However, Vanco cannot guarantee that these

practices will prevent every unauthorized attempt to access, use or disclose personally

identifiable information. Therefore:

a If an unauthorized disclosure occurs, Vanco shall provide notification of the

breach within seven (7) days to the United States Secret Service and the Federal

Bureau of Investigation.

b

Vanco shall wait an additional seven (7) days from its government notice prior to

notifying the affected customers of the breach.

c

Notwithstanding the provisions in subparagraph (b) above, Vanco shall not wait

the additional seven (7) days to notify its customers if Vanco determines there is

an immediate risk of irreparable harm to the customers.

d

Vanco shall maintain records of discovered breaches for a period of at least two

(2) years.


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3

ll employees will be trained as to when they are, and are not, authorized to use CPNI

upon employment with Vanco and annually thereafter.

a. Specifically, Vanco shall prohibit its personnel from releasing CPNI based upon a

customer-initiated telephone call except under the following three (3)

circumstances:

i When the customer has pre-established a password.

ii

When the information requested by the customer is to be sent to the

customer s address of record; or

iii When Vanco calls the customer s telephone number of record and

discusses the information with the party initially identified by customer

when service was initiated

b. Vanco may use CPNI for the following purposes:

i

To initiate render maintain repair bill and collect for services;

ii To protect its property rights; or to protect its subscribers or other carriers

from fraudulent, abusive, or the unlawful use of, or subscription to such

services;

iii

To provide inbound telemarketing, referral or administrative services to

the customer during a customer initiated call and with the customer s

informed consent;

iv

To market additional services to customers that are within the same

categories of service to which the customer already subscribes;

v

To market services formerly known as adjunct-to-basic services; and


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vi

. To market ad

ditional service

s to customers

with the recei

pt of informed

conse

nt via the use of

opt-in or opt-o

ut elections as

applicable.

4 Prior to

allowing acce

ss to customer

s individually

identifiable CP

NI to Vanco s

joint

venturers or

independent c

ontractors, Va

nco will requi

re, in order to s

afeguard that

information,

their entry into

both confidenti

ality agreement

s that ensure co

mpliance with

this St

atement and sh

all obtain opt-i

n consent from

a customer pr

ior to disclosin

g the

informa

tion. In additio

n, Vanco requi

res all outside

dealers and age

nts to acknowl

edge

and

certify that they

may only use

CPNI for the pu

rpose for whic

h that informat

ion has

be

en provided

5 Vanco

requires expres

s written autho

rization from th

e customer prio

r to disclosing C

PNI

to new carrier

s except as oth

erwise required

by law.

6 Vanco doe

s not market sh

are or otherwise

sell CPNI to a

ny third party.

7

Van

co maintains a r

ecord of its ow

n and its affiliat

es sales and ma

rketing campai

gns that

use Vanco s c

ustomers CPN

I. The record w

ill include a de

scription of ea

ch campaign,

the specific C

PNI that was u

sed in the camp

aign and what products and services were

offere

d as part of the

campaign

a. Prior to c

ommencemen

t of a sales or

marketing cam

paign that util

izes CPNI,

Vanco e

stablishes the s

tatus of a custo

mer s CPNI app

roval. The foll

owing sets

forth the pro

cedure followed

by Vanco

i. Prior to any

solicitation f

or customer a

pproval, Van

co will notify

customers of their right to restrict the use of, disclosure of, and access to

their C

PNI


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ii. Vanco will use opt-in approval for any instance in which Vanco must

obtain customer approval prior to using, disclosing, or permitting access to

CPNI.

iii. A customer s approval or disapproval remains in effect until the customer

revokes or limits such approval or disapproval.

iv.

Records of approvals are maintained for at least one year.

v

Vanco provides individual notice to customers when soliciting approval to

use, disclose, or permit access to CPNI.

vi.

The content of Vanco s CPNI notices comply with FCC rule 64.2008(c).

8

Vanco has im plemented a system to obtain approval and informed consent from its

customers prior to the use of CPNI for marketing purposes. This system allows for the

status of a

customer s CPNI approval to be clearly established prior to the use of

that

customer s CPNI.

9

Vanco has a supervisory review process regarding compliance with the CPNI rules for

outbound marketing situations and will maintain compliance records for at least one year.

Specifically, Vanco s sales personnel will obtain express approval of any proposed

outbound marketing request for customer approval of the use of CPNI by the Vanco s

General Counsel.

10 Vanco

notifies customers immediately of any account changes, including address of

record, authentication, online account and password related changes.

11

Vanco m ay negotiate alternative authentication procedures for services that Vanco

provides to business custom ers that have a dedicated account representative and a

contract that specifically addresses Vanco s protection of CPNI.


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12. V

anco is

prepare

d to pro

vide wr

itten no

tice wit

hin five

(5) bus

iness da

ys to th

e FCC

of

any

instance

where

the opt

-in mec

hanism

s do no

t work p

roperly

to such

a degr

ee that

c

onsume

r s inab

ility to o

pt-in is

m ore th

an an a

nomaly

.

Documents

Vanco Solutions 2015 CPNI Certification and Attachment A.pdf