This is a reminder that the filing of CPNI certification is no longer required by the Federal Communications Commission for 2017. A December, 2016 FCC public notice confirmed this change.
The FCC ordered elimination of the 2017 certification as part of its revised privacy rules for telecommunications carriers. These rules require companies to provide notice to customers of their collection activities, obtain consent prior to using or sharing data, implement data security measures and report data breaches.
For 2017, the FCC has adopted a transition to these new privacy rules. Because the CPNI certification requirement is removed on January 3rd, but many of the other rules will not be implemented until late in 2017, carriers are required to follow those existing rules during the transition.
Following is the implementation schedule: (Provisions not listed are effective January 3rd, 2017)
January 3, 2017: CPNI certification eliminated.
Take it or leave it offers prohibited.
March 2, 2017: Implement reasonable data security.
June2, 2017: Follow data breach notification procedures.
December 4, 2017: Provide notice to customers of collection activities.
Obtain customer consent for using or sharing data.
Provide financial incentive rules.
Implementation of some of these rules may be delayed due to Paperwork Reduction Act review, while others may change under President Trump’s FCC. Carriers should therefore maintain all relevant records until this order is finalized.
