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CPNI Policy

HR Co-op Policy Regarding Customer Proprietary Network Information (CPNI)

Hood River Electric & Internet Co-op (HR Co-op) is committed to maintaining the privacy of all its members. In addition to protecting your personal information, as outlined in the HR Co-op’s Privacy Policy, we are obligated to provide additional protections to certain information about how you use your VoIP services.

CPNI Protections

As a user of our VoIP services, you have the right, and HR Co-op has a duty, under federal law, to protect the confidentiality of certain types of VoIP related services, including:

  1. Information about the quantity, technical configuration, type, destination, location, and amount of your use of your VoIP usage
  2. Information contained on your VoIP bill concerning the services that you receive.

That information, when matched to your name, address, and VoIP number is known as “Customer Proprietary Network Information” or CPNI. Examples of CPNI include information typically available from VoIP-related details on your monthly bill, technical information, type of service, current VoIP charges, long distance and local service billing records, directory assistance charges, call usage data and calling patterns. CPNI does not include your name, address and VoIP number, as this is common publicly available information. CPNI protections do not extend to internet access services.

Giving Permission

When you contact our office, we will ask for your permission to access your phone service data in order to serve you.

You do have the right to restrict our use of your CPNI at any time. If you deny or restrict your permission for use of your CPNI, you will suffer no effect, now or in the future, on how we provide VoIP services to which you subscribe.

Customer Authentication

Federal privacy rules require HR Co-op to authenticate the identity of its customer prior to disclosing CPNI. Customers contacting our office can discuss their services and billings with a HR Co-op representative once that representative has verified the caller’s identity. There are three methods by which we will conduct customer authentication:

  1. By having the customer provide a pre-established password and/or PIN; by having the customer provide a pre-established password created at the time of their account set up.
  2. By calling the customer back at the VoIP number associated with the services purchased.
  3. By emailing, if applicable, the requested documents to the customer’s email address on record.

Passwords and/or PINs may not be any portion of the customer’s social security number, mother’s maiden name, VoIP number associated with the customer’s account or any pet name. In the event the customer fails to remember their password and/or PIN, our HR Co-op representative will ask the customer a series of questions known only to the customer and HR Co-op, i.e. security questions 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

HR Co-op 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 “security question and answer”) is created or changed, HR Co-op will notify the account holder by either the E-mail address that they provided or by mailing the notification to their address of record. Additionally, after an account has been established, when a customer’s address (whether postal or E-mail) changes or is added to an account, HR Co-op will also send a confirmation notification.

Disclosure of CPNI

HR Co-op may disclose CPNI in the following circumstances:

  • When the customer has provided permission for the use of their CPNI;
  • When disclosure is required by law or court order.
  • To protect the rights and property of HR Co-op 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) or Local Port freeze on their account; or
  • For directory listing services to be provided.
  • To provide the services to the customer, including customer reported trouble management.
  • To bill the customer for services.

Protecting CPNI

HR Co-op uses numerous methods to protect your CPNI. HR Co-op employees are trained on how CPNI is to be protected and when it may or may not be disclosed. All marketing campaigns are reviewed by an HR Co-op supervisor to ensure that all such campaigns comply with applicable CPNI rules. HR Co-op does not market or sell CPNI to any third party.

HR Co-op will not release CPNI during customer-initiated VoIP contact without first authenticating the customer’s identity in the manner set-forth herein. Violation of this CPNI policy by any HR Co-op employee will result in disciplinary action as set-forth in the HR Co-op Employee Handbook.

Breach of CPNI

Protections in the event HR Co-op experiences a privacy breach and CPNI is disclosed to unauthorized persons, Federal rules require HR Co-op to report such breaches to law enforcement. Specifically, HR Co-op will notify law enforcement no later than 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. HR Co-op cannot inform its customers of the CPNI breach until at least 7 days after notification has been sent to law enforcement, unless the law enforcement agent instructs the carrier to postpone disclosure pending investigation. Additionally, HR Co-op is required to maintain records of any discovered breaches, including the date that the breach was discovered, 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. HR Co-op will retain these records for a period of no less than 2 years.

Annual CPNI Certification

Pursuant to FCC regulations, 47 C.F.R. § 64.20089(e), HR Co-op will annually submit to the FCC, prior to March 1st, a CPNI Certification of Compliance and accompanying Statement regarding its CPNI policies and operating procedures. These documents certify that HR Co-op complied with federal laws and FCC regulations regarding the protection of CPNI throughout the prior calendar year.