BRANDENBURG TELEPHONE COMPANY

200 Telco Drive

PO Box 599
Brandenburg, KY 40108

270422-2121

february 5,2015

Via

IjCFS

Marlene H. Dortch, Secretary

Office of the Secretary, Federal Communications Conmissiol
445 l2th Streer, SW. Suite'lW-A125
Washirgton, DC 20554

RE: CPNI Cefiification and StatemeDt Filinc

Dear Ms. Dotch:
Pursuant to Section 64.2009(c) ofthe Commission's Rules. I hercby submit the attached
annual Customer Proprietary Network lnfonnation Ceftiflcate and accornpanJing
statemcnt on bchalf of Brandenburg Telephone Company. lDc.

Should you liave any questions or need luther infomation. please contact nlc.

Slncqely.

y,/1tnt

-.

A.llkon \\'illoughhl
Geneml Manager

cc:

Best Copy and Prinring. lnc. via email to ICCa@.BqPIYEB.I]QU[

BRANDENBURG TELEPHONE COMPANY

200 Telco Drive
PO Box 599

Brandenburg, KY 40108
270422-2121

BE!ORF]
TI I lr I, l-.DFIRAL COMMUNIC-/\TIONS CONIMISSION
WASHINGTON. D,C, 20554

.EB Docket

ANNUAL

,17

C.F.R

No. 06-16

6,1.2009(e) CPNI

CERTIFICATION

Annual 64.2009(e) IIPNI Cefiilication tbr 201,1

Date filed: Ijcbruary 5. 2015
Name of compan,v covered by this certiflcation: Brandenburg Telephone Company. Inc.

Form 499 Filer lD: 801339 FRNr 0004995429

Name of signalory: Allison Willouqhbv

Title of signatory: General Manaser

I, Allison Willor-rghby cefii that I am an olflcer oflhe compant named above. and
acting as an agent ofthe compan). that I have personal kno\.\,ledge that the company has
cstablishcd opc.ating procedurcs that are adequate to ensure compliance u,ith thc Conrmission s
CPNI rules. See 47 C.F.R. t 61.2001 et se(j.
Attached to this certjfication is an accompanying stalement explaining horv the
companv's procedures ensure that the company is in compliance u,ith the requirements set forth
ln section 64.2001 er.re./. ofthe Commission's rules.

Thc company has not taken any actions (proceedings instituted or petitions tilcd by a
company a1 either state commissions, the couit system or at the Commission) against dala
brokers in the pasl,year. Companies must repoft oI1 any inlbrmation that they have *ith respcct
to the proccsses pretexters are using to attempt to access CPNI, and what steps comfanics cre
takirg to protect CPNI.

'Ihe company has not received any cltstomer complaints in the pasl year coltceming tfie
unaulhorized releAse of CPNI.

Signed:

Allisbn Willoughby
General Manager

Dated: febmary 5,2015

BRANDENBURG TELEPHONE COMPANY

200 Telco D.ive
PO Box 599

Brandenburg, KY 40108
270422-2121

Blandenburg Telephone Conrpany, Inc.

FCC 499 Filer ID: 801i39 l-RN: 0004995429

P.O. Box 599 Brandenburg.

KY

40108

STATEMENT OF FCC CPNI RULE COMPLIANCE

fhis

statemenl senes to explain ho\i Brandenburg Telepholle Conpany. Inc. (collectively the
"Company') is complying rvith Federal Commu'iications Commission ("fCC") rules rclated to
the privacy of customcr information. The type of inlbrmation lbr rvhich customer privacy is
protected by the ICC'S rules is called "customer prop etary network information" ("CPNI').
fhe ICC'S rules restricting telecommunications compan-\'- use oI CPNI are contained at Pan 6.1.
Subparl U ofthe FCC's rules (47 C.F.R. S 64.2000-2009).

1.

Dutv to Protect CPNI

We reoognize our duty to protect custonler CPNL We may not disclose CPNI to
unauthodzed persons, nor may we use CPNI in cefiain u'a,vs \\'ithout consent fiom our customers.
llcforc u,e can provide cuslomels u,ith their o$n CPNI. we must authenticate the cusknncr.
We recognize that there are a feu,cases in r.vhich rve can disclose CPNI $ithout flrst
obtailing customer approval :

i.
ii.
iii.

Administrativc

use: We nray

use CPNI 1() iniliate. render.

bill

and collect far

commLmications selvices.
Protection of canier and third parties: We n1a)'. use CPNI to protcct the interests of
our company. such as to prcvcnt fraud or illegal use of our syslems and net\&ork.
Employees are notified olthe steps to takc. ifany, in thesc sorts of situations.
As requircd by lau': we may disclose CPNI if we are required to by law, such as
through lcgal process (subpocnas) or in response to requests by la$, enlbrcement.
Ernplolees aie notilied ofany stcps the-v must take in these situations.

2.

Our

t.lse

of CPNI in Marketing

The Compan! does not use CPNI for marketiig ptuposes except

i.
ii.

in

the following

to market sefl,ices to our existing customers uithin the catcgories o1'service to \\licl1
the customer already subscribes.
to provide CPE and call anslrering. voice mail or messaging, voice stomge and
ret eval selviccs, fax store and forward, and prolocol conversion.

For marketing puposes lbr which usc ofCPNI would otherwise requile permission from
thc Customers, the Company uses only Customer billing nanre and address and/or tclcphonc
number without any segregation or rellnement based on CPNI. On inbound and administratile
calls. howcvcr. the Conrpany may utilize CPNI in its sales and marketing effofts b,v first
requesting pemission to do so pursuant to $64.2008(f). Tn those cases, thc Companl rccognizes
that permission to rise CPNI ends when thc call tenninates and thc Customer is lirlly irllbnned
that he may refLLse the permission.
We regularly revieu,our marketing practices to deteimine whcn, ho* and if CPNI is usecl
within the Company to insue that \.1e remain in contpliance u,ith the FCC s CPNI regulations
and with our policy as desc b(]d here in. ln thc unlikely event that Co,npany clecides to modifi
its policies for use of CPNI, it will insurc that its new policy full,v complies with fCC CPNI rules
including, but not limited to, tracking and Customer notice provisions contained in S64.20082009.

3.

Authentication Prior to Disclosure of CPNI

We undelsland thal $'e are required to detemine that any request for CPNI rvill not be
released without authenticating the authorit) ofthe requestor to receivc such inlbnnation.
We undcrstand that rvhen a customer calls. \.1e may not release CPNI until we ha\'e
authenticated the release of the information to thc requestor in a maniicr consistent \rith CPNI
regulations.

{.

Employee Issues

AII of our enployecs were trained rcgarding the compan,v's CPNI policies u'l]ich u'ere
cffective December 8, 2007. To maintain compliance with ICC rules aftcr December 8. 2007.
the Company developed a manual and identil-red a compliance olllcer to address any CPNIrelated issues that ma,v arise. The Company has established procedurcs and trained emplol-ees
having access 10, or occasion to use custoner data, to idcnti8 B'hat customer infomatioo is
CPNI consisient \rith the definition ofCPNl under the FCC's revised CPNI rules'Ihe Compan_v 1'las implemented a training procedure for all new hires and contractors
legarding the Company's praclices regarding CPNL
In addition. the Company has in placc an express disciplinary process to addiess an)
unauthorized usc of CPNI where the circunNta[ces indicate authorization is required under thc
FCC's CPNT rrrles.

5.

Notifications to Customers

custome$ wlten changes have bccn made to passwords (if applicable)'

addresses of rccord. and authorized users by mailing a notitication to the account addrcss of
record. The notice does not contaii information regarding thc changes.

we notily

6.

Record-Kecping
We maintain the following records in our files for at least tB'o "vears:
Employee disciplinary rccords. ifapplicablc; and
If applicable: 1) records of discovered CPNI breaches 2) notjfications to law
enfoicement regarding breaches. and 3) any responses iiom law enlbrcement
regarding those breaches.

i.
ii.
7.

Unauthorized Disclosure Ol CPNI

We undersiand that $'i] must repoft CPNI breaches to ialv enforcemcnt no later than sevcn
(7) business days affer determining the breach has occurred. by sending electronic notificalion
through fie lirk at httpt44ryiErgq!9ue?ll! to the cenfal reporting facjlitv, rvhich will thcn
noiitr the United States Secret Se r'icc (IISSS) and the fedcral Bureau oflnvestigatjon (FBI)'
We understa,rd that \\e may not notiry customers or the public of the breach eerlier than
seven (7) da,vs after we havc notihed lau'enforcement through the central repofiing facility' II'
we wish to notili customers or the public immediately, wherc \\'e leel that there is "an
jrreparable harm," lle inform la\
extraordinarily urgcnt need to rotify" to avoid "inmediale and
enfbrcement ofour desire to notily and comply wjth 1aw enforcement s directiolts
During the course of the year, we compile information rcgarding pretexter attenpts to
gajn improper acccss to CPNI, including any breaches or attempted breaches' we include this
inlbrmation.in our annugl CPNf,compll6Ile ccftilication filed with the FCC.
Signed:
I

Dated: Iebruary 5. 2015