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Customer Privacy Policy filed with the Federal Communications Commission January 2, 2020 [PDF]

Carolina Digital Phone, Inc. 

Accompanying Statement to Annual Certification of CPNI
Steps Taken By Company to Ensure the Confidentiality of CPNI Records
January 2, 2020

Carolina Digital Phone Inc., is a Registered Interconnected VoIP Provider as listed with the Federal Communications Commission FCC Registration Number (FRN) is 002-13989-38 and our FCC Filer ID at FCC Filer ID 829591. As a provider of telecom services under the license by the FCC International calling under Section 214 we are granted the authority to provide resale service in accordance with section 63.18(e)(2) of the Commission’s rules posted at the FCC Public Notice dated April 4, 2013, 47 C.F.R. § 63.18(e)(2) international calling termination.

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 customer’s 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:

  1. Failure by an employee to abide by the applicable CPNI policies and procedures is cause for discipline, up to and including employment termination.
  2. All Company employees during their annual Human Resources Policy review receive an overview of CPNI requirements.
  3. All customer-interfacing employees are required to attend CPNI training prior to receiving access to customers’ CPNI call detail information.
  4. Only job positions with  need to know business are given access to CPNI call detail records.
  5. 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.
  6. 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.