CPNI

Policies and Procedures

Affordable Phone Services, Inc. has implemented the following internal policies and
procedures in order to ensure compliance with the requirements of Section 222 of
the Communications Act of 1934 and the FCC’s rules governing CPNI, codified at 47
C.F.R. § 64.2001 et seq.

AFFORDABLE PHONE SERVICES, INC. has adopted practices and procedures that
manage the disclosure of CPNI:

• AFFORDABLE PHONE SERVICES, INC. does not disclose or release CPNI upon
a customer’s request.
• AFFORDABLE PHONE SERVICES, INC. does not disclose or release CPNI via
online account access.
• AFFORDABLE PHONE SERVICES, INC. does not have any retail locations
where a customer’s CPNI can be obtained.
• All customers calling in to request CPNI are advised to contact their local law
enforcement in order to acquire call details and other related information due
to the level of restrictions that AFFORDABLE PHONE SERVICES, INC. has in
place regarding access to call detail CPNI from our daily operating systems.
○ AFFORDABLE PHONE SERVICES, INC. will not assist in supplying CPNI
to any law enforcement agency that does not produce a valid legal
demand.
• AFFORDABLE PHONE SERVICES, INC. provides annual training which includes
updates as deemed necessary by changes in CPNI, internal changes that
require additional CPNI training or whenever management deems it
necessary in order to ensure compliance. The training expresses when to
and when not to use CPNI.
• A clear discipline process is in place which clearly outlines steps that will be
taken against any employee for any unqualified use of CPNI.
• Record keeping in each department is current and adequate to meet the
requirements as set forth in section 64.2001 et seq. of the commission’s
rules.

The aforementioned procedures ensure that Telecom Service Bureau is in

compliance with the FCC’s CPNI Rules.