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Inside Privacy Updates on Developments in Global Privacy & Data Security from Covington & Burling LLP

CPNI Certifications Due on March 1

Posted in Federal Communications Commission

As a reminder, telecommunications carriers must submit their annual certifications regarding customer proprietary network information (CPNI) by March 1.  CPNI is private customer information concerning telecommunications. Telecommunications carriers and providers of interconnected Voice over Internet Protocol (VoIP) must certify annually to the FCC that they comply with their obligations to protect and limit disclosure of CPNI.

Annual certifications must contain the following information: 

  • Certificate signed by an officer stating that the officer has personal knowledge that the company has established operating procedures adequate to ensure compliance with the CPNI rules;
  • Written statement explaining how its operating procedures ensure compliance;
  • Statement of whether the company has taken any actions against data brokers in the past year, and if so an explanation of such actions; and
  • Statement of whether the company has received any consumer complaints in the prior year concerning CPNI, and summary of such complaints if any. 

The FCC provides a template for use.  The FCC monitors compliance with the annual certification requirement closely and routinely issues forfeitures (regulatory fines) against non-compliant companies.