As a customer of our services, you have the right, and Columbus Telephone Company has a duty, under federal law, to protect the confidentiality of certain types of services, including: (1) information about the quantity, technical configuration, type, destination, location, and amount of your use of your services, and (2) information contained on your telephone bill concerning your services you receive. That information, when matched to your name, address, and telephone number is known as “Customer Proprietary Network Information,” or “CPNI.”
CPNI does not include things like customer name, address, or telephone number; aggregate information or data that is not specific to a single customer; customer premises equipment; and Internet access services.
Customer proprietary network information (“CPNI”) is information related to the quantity, technical configuration, type, destination, location, and the amount of telecommunications a customer uses that Columbus Telephone Company has access to by virtue of the customer-provider relationship. CPNI does not include the Customer name, address and telephone number, nor does it include Internet access services.
From time to time, Columbus Telephone Company would like to use the CPNI information it has on file to provide you with information about Columbus Telephone Company’s communications-related products and services or special promotions. Columbus Telephone Company’s use of CPNI may also enhance its ability to offer products and services tailored to your specific needs. Accordingly, Columbus Telephone Company would like your approval so that Columbus Telephone Company may use this CPNI to let you know about communications-related services other than those to which Customer currently subscribes that Columbus Telephone Company believes may be of interest to Customer. IF YOU APPROVE, YOU DO NOT HAVE TO TAKE ANY ACTION.
However, you do have the right to restrict our use of your CPNI. YOU MAY DENY OR WITHDRAW COLUMBUS TELEPHONE COMPANY’S RIGHT TO USE YOUR CPNI AT ANY TIME BY CALLING 620-429-3132. If you deny or restrict your approval for Columbus Telephone Company to use your CPNI, you will suffer no effect, now or in the future, on how Columbus Telephone Company provides any services to which you subscribe. Any denial or restriction of your approval remains valid until your services are discontinued or you affirmatively revoke or limit such approval or denial.
1) by having the Customer answer an authentication question, or;
2) by calling the Customer back at the telephone number associated with the services purchased
Passwords and/or PINs may not be any portion of the Customer’s social security number, mother’s maiden name, amount, or telephone number associated with the Customer’s account or any pet name. In the event the Customer fails to remember their password and/or PIN, Columbus Telephone Company will ask the Customer a series of questions known only to the Customer and Columbus Telephone Company in order to authenticate the Customer. In such an instance, the Customer will then establish a new password/PIN associated with their account.
NOTIFICATIONS OF CERTAIN ACCOUNT CHANGES
Columbus Telephone Company will be notifying customers of certain account changes. For example, whenever an online account is created or changed, or a password or other form of authentication (such as a “secret question and answer”) is created or changed, Columbus Telephone Company will notify the account holder. Additionally, after an account has been established, when a customer’s address (whether postal or e-mail) changes or is added to an account, Columbus Telephone Company will send a notification. These notifications may be sent to a postal or e-mail address, or by telephone, voicemail or text message.
DISCLOSURE OF CPNI
Columbus Telephone Company may disclose CPNI in the following circumstances:
- When the Customer has approved use of their CPNI for Columbus Telephone Company or Columbus Telephone Company and its joint venture partners and independent contractors (as the case may be) sales or marketing purposes.
- When disclosure is required by law or court order.
- To protect the rights and property of Columbus Telephone Company or to protect Customers and other carriers from fraudulent, abusive, or unlawful use of services.
- When a carrier requests to know whether a Customer has a preferred interexchange carrier (PIC) freeze on their account.
- For directory listing services.
- To provide the services to the Customer, including assisting the Customer with troubles associated with their services.
- To bill the Customer for services.
Columbus Telephone Company uses numerous methods to protect your CPNI. This includes software enhancements that identify whether a Customer has approved use of its CPNI. Further, all Columbus Telephone Company employees are trained on the how CPNI is to be protected and when it may or may not be disclosed. All marketing campaigns are reviewed by a Columbus Telephone Company supervisory committee to ensure that all such campaigns comply with applicable CPNI rules.
Columbus Telephone Company maintains records of its own and its joint venture partners and/or independent contractors (if applicable) sales and marketing campaigns that utilize Customer CPNI. Included in this, is a description of the specific CPNI that was used in such sales or marketing campaigns. Columbus Telephone Company also keeps records of all instances in which CPNI is disclosed to third parties or where third parties were allowed access to Customer CPNI.
Columbus Telephone Company will not release CPNI during customer-initiated telephone contact without first authenticating the Customer’s identity in the manner set-forth herein. Violation of this CPNI policy by any Columbus Telephone Company employee will result in disciplinary action against that employee as set-forth in Columbus Telephone Company’s Employee Manual.
BREACH OF CPNI PRIVACY
In the event Columbus Telephone Company experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require Columbus Telephone Company to report such breaches to law enforcement. Specifically, Columbus Telephone Company will notify law enforcement no later than seven (7) business days after a reasonable determination that such breach has occurred by sending electronic notification through a central reporting facility to the United States Secret Service and the FBI. A link to the reporting facility can be found at: www.fcc.gov/eb/cpni. Columbus Telephone Company cannot inform its Customers of the CPNI breach until at least seven (7) days after notification has been sent to law enforcement, unless the law enforcement agent tells the carrier to postpone disclosure pending investigation. Additionally, Columbus Telephone Company is required to maintain records of any discovered breaches, the date that Columbus Telephone Company discovered the breach, the date carriers notified law enforcement and copies of the notifications to law enforcement, a detailed description of the CPNI breach, including the circumstances of the breach, and law enforcement’s response (if any) to the reported breach. Columbus Telephone Company will retain these records for a period of not less than two (2) years.
NOTIFICATION OF CHANGES TO THIS POLICY
If we change this CPNI Policy, we will post those changes on www.columbus-telephone.com or in other places we deem appropriate, so that you can be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If you decide to continue receiving your services after we make any changes to this the CPNI Policy, you shall be deemed to have given express consent to the changes in the revised policy.
Federal privacy rules require Columbus Telephone Company to authenticate the identity of its customer prior to disclosing CPNI. Customers calling Columbus Telephone Company’s office can discuss their services and billings with a Columbus Telephone Company representative once that representative had verified the caller’s identity. There are three methods by which Columbus Telephone Company will conduct customer authentication: