Carolina Digital Phone
Accompanying Statement to Annual Certification of CPNI
Steps Taken By Company to Ensure the Confidentiality of CPNI Records
February 1, 2015
Carolina Digital Phone is a small company and reseller of telecommunications services. Our primary business is as an Internet Services Provider for web site hosting, email applications and hosted VoIP telecommunications services.
Many of our customers are governmental agencies, libraries and schools, where projects are awarded through a public bid process or through the E-rate system. For those customers, Carolina Digital Phone performs marketing primarily through federal, state and local government public bid processes. Our company follows the rules for each bid, which ensure fairness for each bidder.
We as a company simply do not use customers’ CPNI (or other private customer information) in marketing or otherwise, nor do we sell or give private customer information or CPNI to third parties.
All private customer information is kept secure. Security practices are maintained in compliance with federal government encryption standards and in accordance with the terms of our contracts with the government.
Our Company Policy with regard to CPNI and employee handling of CPNI is as follows:
- Failure by an employee to abide by the applicable CPNI policies and procedures is cause for discipline, up to and including employment termination.
- All Company employees during their annual Human Resources Policy review receive an overview of CPNI requirements.
- All customer-interfacing employee are required to attend CPNI training prior to receiving access to customers’ CPNI call detail information.
- Only job positions with business need to know are given access to CPNI call detail records.
- Company has trained all personnel with access to CPNI as to the identification of CPNI and when CPNI may be used and has an express disciplinary process in place for any improper use of CPNI.
- No outbound sales and marketing campaigns are conducted without management approval and any such campaign would require supervisory review to assure compliance with the CPNI rules.