Fine Print: What the Communications Act Says About CPNI
Section 222(h) states:
(1) Customer proprietary network information
The term “customer proprietary network information” means—
(A) information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer of a telecommunications carrier, and that is made available to the carrier by the customer solely by virtue of the carrier-customer relationship; and
(B) information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of a carrier; except that such term does not include subscriber list information.
Section 222(c) states:
Confidentiality of customer proprietary network information
(1) Privacy requirements for telecommunications carriers
Except as required by law or with the approval of the customer, a telecommunications carrier that receives or obtains customer proprietary network information by virtue of its provision of a telecommunications service shall only use, disclose, or permit access to individually identifiable customer proprietary network information in its provision of (A) the telecommunications service from which such information is derived, or (B) services necessary to, or used in, the provision of such telecommunications service, including the publishing of directories.
Verizon’s Revised CPNI Language
The revised CPNI/Confidentiality language appears below with emphasis added to the new language in red. It was excerpted from Verizon’s website on May 18:
[LB3 note: recommend downloading and saving this language because VZ may take it down/modify it.]
Customer Consent to Use […] of Customer Proprietary Network Information (”CPNI”). Verizon acknowledges that it has a duty, and Customer has a right, under federal and/or state law […] to protect the confidentiality of Customer's CPNI. In order to better serve Customer and offer additional products and services, Verizon, Verizon Wireless and their affiliates (“Verizon Companies”) may need to share Customer’s CPNI and Confidential Information. CPNI includes information relating to the quantity, technical configuration, type, destination, location, and amount of use of the […] telecommunications and interconnected voice over Internet Protocol services Customer purchases from the Verizon Companies, as well as related local and toll billing information, made available to the Verizon Companies solely by virtue of Customer’s relationship with the Verizon Companies. With Customer consent, the Verizon Companies may share Customer CPNI and other Confidential Information among the Verizon [...]Companies, and with Vodafone, agents, contractors and partners, so that all may use this information to offer Customer the full range of products and services offered by […] them, including local, long distance, wireless, and Internet services (see www.verizon.com for a description of Verizon companies and services). By signing […] this Agreement, Customer consents to the Verizon Companies using and disclosing Customer CPNI and Confidential Information as described above. Customer may refuse CPNI consent by signing […] this Agreement and by notifying Verizon in writing at firstname.lastname@example.org and email@example.com of Customer’s decision to withhold Customer’s consent. Customer’s consent or refusal to consent will remain valid until Customer otherwise advises Verizon, and in either case, will not affect Verizon’s provision of service to Customer.
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Justin G. Castillo and Ellen G. Block
Levine, Blaszak, Block & Boothby, LLP