Annual 47 C.F.R. § 64.2009(e) CPNI Certification
EB Docket 06:56
Annual 64.2009(e) CPNI Certification for 2017 covering the prior calendar year 2016
Date Filed: March 31, 2017
[Name of Company(s) Covered by this Certification: Roekford Telephone Company,
Form 499-A Filer ID: 829337
Name of Signatory: R. Steven Hale
Title of Si
tory: CEO/President
1, R. Steven Hale, ceniy that | am an officer of the company named above, and acting as an agent
of the company, that I have personal knowledge thatthe company has established operating procedures that
are adequate to ensure compliance with the Commission’s CPNI rules.
‘Attached to this certification is an accompanying statement explaining how the company's
procedures ensure that the company is in compliance with the requirements (including those mandating the
adoption of CPNI procedures, training, recordkeeping, and supervisory review) set forth in section 64.2001
et seg. of the Commission's rules.
‘The company has not taken actions (ie., proceedings instituted or petitions filed by a company at
either state commissions the court system, or atthe Commission against data brokers) against data brokers
inthe past year
‘The company has not received customer complaints in the past year concerning the unauthorized
release of CPNI.
‘The company represents and warrants that the above certification is consistent with 47 C.F.R. §
1.17, which requires truthful an accurate statements to the Commission. The company also acknowledges
that false statements and misrepresentations to the Commission are punishable under Title 18 of the U.S.
‘Code and may subject it to enforcement actions.
Steven HateRockford Telephone Company, Inc. markets exclusively to other telecommunications cari
businesses, and institutions. No services are curently sold to consumers. As such, Rockford Telephone
Company, Inc.'s service agreements are negotiated with each customer, including the requirements to
safeguard customer information, Through the negotiation of these agreements, each customer
acknowledges: 1) thatthe use of CPNI for any purpose other than to further te delivery of services; and 2)
disclosure or revelation of the CPN! to any person or entity other than its employees, directors. officers,
agent, and consuttants who have a need to know to further the detivery of services and are subject o legally
binding obligations of confidentiality and non-use no less restrictive than those contained inthe agreement
between the companies by Rockford Telephone Company. In. is strictly forbidden and will result in
immediate severance and possible prosecution to the fllest extent ofthe law. During the term of any
agreement, customers designate their vendor interfacing personnel who have the authority to release
‘customer's CPNI under the terms of the agreement to their dedicated Rockford Telephone Company, Ine
account representative(s).