All of BartNet's employees are aware that disclosure of our customers' CPNI information without obtaining the proper customer approval is a violation of the FCC's rules set forth in 47 U.S.C. 222 and Subpart U of Title 47 of the Code of Federal Regulations; 47 C.F.R. 64.2001 through 64.2009.

BartNet has internal procedures in place to educate its employees regarding the FCC's rules and regulations as to the release of CPNI information. The employees that have access to this information are aware that the FCC prohibits the disclosure of such information without the proper customer consent and as allowed by law and the FCC's rules.

​

 

• Any employee that violates BartNet's CPNI policies is subject to disciplinary action, up to dismissal.

• BartNet mandates yearly CPNI training for employees to ensure compliance with any new regulations.

• BartNet has implemented safeguards for our customers' protection against pretexters consistent with the FCC's requirements in Section 47 C.F.R. 64.2010.

 

All requests for subscriber CPNI are forwarded to Senior Management personnel and any unauthorized use, sale, or disclosure of CPNI by any employee would subject the employee to disciplinary action, up to and including dismissal.

Authentication Requirements
BartNet prohibits its employees from releasing a customer's records when a customer calls except when the customer provides a password. If a customer does not provide a password, BartNet will not release the customer's records except by sending it to an address of record or by calling the customer at the telephone of record. BartNet also provides mandatory password protection for online account access. BartNet will provide all CPNI records as may be required by law and proper legal documentation is required prior to release of records.

Notice to Customer of Account Changes BartNet notifies the customer immediately when the following are created or changed: (l) a
password; (2) a back-up for forgotten passwords; (3) the address of record, or (4) an online account.

Joint Venture and Independent Contractor Use of CPNI
Torah requires explicit consent from a customer before disclosing their CPNI to a joint venture partner or independent contractors for the purposes of marketing communications-related services to that customer.

​

Business Customer Exemption
BartNet may bind itself contractually to authentication regimes other than those described in this Section for services it provides to its business customers that have both a dedicated account representative and a contract that specifically addresses the Company's protection of CPNI.

Notice of Unauthorized Disclosure of CPNI
A notification process is established for both law enforcement and BartNet customers in the event of a CPNI breach. BartNet's Senior Management shall notify law enforcement of a breach of its customers' CPNI no later than seven business days after a reasonable determination of a breach by sending electronic notification to the United States Secret Service (USSS) and the Federal Bureau of Investigation (FBI). BartNet may notify the customer and/or disclose the breach publicly after seven business days following notification
to the USSS and the FBI, if the USSS and the FBI have not requested to postpone the disclosure.

However, BartNet may immediately notify a customer or disclose the breach publicly after consultation with the relevant investigative agency, if BartNet believes that there is an extraordinarily urgent need to notify a customer or class of customers in order to avoid
immediate and irreparable harm.

Additionally, BartNet will maintain a record or any discovered breaches, notifications to the USSS and the FBI regarding those breaches, as well as the USSS and the FBI response to the notifications for a period of at least two years. These records will include, if available, the date that BartNet discovered the breach, the date that BartNet notified the USSS and the FBI, a detailed description of the CPNI that was breached, and the circumstances of the breach.

Opt-in/ Opt-Out Approvals
BartNet maintains records of all opt-in and opt-out approvals by customers, including a history of notices to customers. All outbound marketing campaigns are approved by the General Manager.