Your Privacy Is Our Responsibility
Southern Montana Telecommunications Policy & Procedure Subject: Privacy & CPNI
Policy: It is the policy of Southern Montana Telecommunications to maintain privacy for all subscribers and to ensure that all SMT and regulatory agency guided standards are met. This includes the protection of Customer Proprietary Network Information (CPNI) as outlined in the FCC.
PURPOSE: This policy is a public policy available to SMT administration and staff, SMT subscribers, and any vendors or third-party service providers to guide the process SMT uses to collect, use, and protect subscriber information.
Section II CPNI Policy
When a subscriber establishes an account for services, a variety of information is required to create a service relationship. Personal information such as name, address, telephone number, in addition to social security and driver’s license information may be required for billing and payment purposes. SMT may also collect information about service options or long-distance selections. If a subscriber rents the residence where service is requested, SMT may require landlord consent or information to install facilities or services. SMT may also collect protected information when subscribers ask for support, have questions about a bill, respond to surveys or emails, engage in conversations, register for information, or participate in promotions or contests. Besides, SMT may combine subscribers’ personal information collected as a part of regular business operations with personal information obtained for marketing purposes (See subscriber’s right to limit or restrict uses of personal information in Policy Section II – CPNI Policy).
A. Use of Personal Information – SMT is authorized to collect the personal information necessary to provide services.
SMT is prohibited from collecting subscribers’ personal information for any other purpose without your consent. SMT considers the personal information contained in our business records to be confidential; however, SMT is authorized to disclose personal information for three general purposes.
1. We may be required by law or legal process to disclose information to law enforcement personnel or other parties in connection with litigation.
2. We may disclose the names and addresses of subscribers for business-related purposes.
3. We may disclose the information necessary to provide your services.
The use of personal information includes, but is not limited to, the following examples:
B. Information Collected During Use of Service – When subscribers use services, SMT transmits information to provide subscriber services. Originating and terminating call data, such as the times, long-distance providers used, and the duration of calls is stored for billing services.
We may contract with third-party providers to provide specific services and features for subscriber services. If third-party providers use any personal information, they will collect, disclose, and protect personal information following the practices stated herein.
1. SMT Communications – On a routine basis and in the normal scope of business operations, SMT will communicate with subscribers in a variety of ways.
2. Special Offers & Updates – Subscribers may receive information from SMT via U.S. mail, e-mail, and other means to provide service-related announcements and information on SMT services that may be of interest (See Do Not Call/Do Not Mail section below).
3. Customer Service – SMT may regularly communicate with subscribers to provide requested services and support for questions and issues relating to a subscriber’s account.
4. Do Not Call/Do Not Mail Lists – SMT is authorized to use subscriber contact information to place telephone calls or to sent print literature for marketing or promotional purposes. Subscribers may, at any time, put their name on the SMT “Do Not Call” or “Do Not Mail” lists so that they do not receive promotional calls or mail. (See subscriber’s right to limit or restrict uses of personal information in Policy Section – CPNI)
5. SMT Website – The SMT website is a regularly updated communication tool. SMT may include within the website links to other websites or information sources. SMT is not responsible for the privacy practices of linked sites.
C. Security – SMT follows industry-standard practices to protect subscribers’ personal information from unauthorized access.
D. Correcting and Accessing Information – Subscribers may examine and copy personal information we collect and maintain upon reasonable notice during regular business hours. We may be unable to provide individual records without a subpoena, court order, or search warrant. SMT reserves the right to charge a fee for the production of any documents.
Information is corrected on a going-forward basis when the personal information we have collected is inaccurate. SMT can't correct information appearing in vendor directory lists until the next available publication of those directory lists. Further, SMT has no control over information appearing in the directory lists or directory assistance services of directory publishers or directory assistance providers not affiliated with SMT.
E. Retention of Information – SMT maintains subscriber information in our regular business records while subscribers are active and for some time after. The period information kept is based on typical business, legal or regulatory requirements. If there are no pending requests, orders, or court orders for access to this data, we may destroy the information after it is no longer necessary.
II Customer Proprietary Network Information (CPNI) Policy
SMT is committed to maintaining subscriber privacy. In addition to protecting personal information, SMT is obliged to give additional protections to certain information about which displays how subscribers use their services. This information is known as Customer Proprietary Network Information or CPNI.
A. Definition of CPNI – CPNI is the information about the quantity, technical configuration, type, destination, location, and the amount of subscriber use. It is also the information contained on a subscriber telephone bill concerning the services subscribers receive. That information, when matched with a subscriber’s name, address, and telephone number, is known as “Customer Proprietary Network Information” or “CPNI.” Examples of CPNI are:
CPNI is not:
B. Authentication Requirements – Following the FCC amendments to CPNI regulation on August 2, 2007, SMT will utilize new authentication methods to establish subscriber identity. Customers of SMT must be authenticated before releasing any CPNI in one of the following three methods:
C. When Can SMT Disclose CPNI
D. Use Approval for CPNI – The use of CPNI enhances the ability of SMT to offer products and services tailored to a subscriber’s specific needs; this could include any communications products and services or special promotions.
SMT will send out notices once every two years explaining subscriber rights related to CPNI; this will include directions for subscribers to restrict CPNI use. If a subscriber denies or restricts the use of CPNI, the restriction remains in effect until services are discontinued, or the subscriber affirmatively revokes the request.
Unless a subscriber contacts SMT and restricts the use of CPNI, it is the policy of SMT to assume that all subscribers approve the use of CPNI.
E. Protecting CPNI – SMT uses numerous methods to protect subscriber CPNI. This process begins with software enhancements that display whether or not a subscriber has approved the use of their CPNI. Other ways SMT protects CPNI are as follows: