>RCN February 26,2016 Maclene H. Dortch Office of the Secretary Federal Communications Commission 445 12th Street, SW, Suite TW-A325, ‘Washington, DC 20854 RE: RCN Telecom Services (Lehigh) LLC (ID 828462) RCN Telocom Servves of Massachusetts, LLC (formerly, RCN BecoCom, LLC (1D 814887) RCN Telecom Serces of Minois, LLC (ID 820149) RCN Telecom Services of Philadelphia, LLC (ID 812061) [RCN Telecom Services of New York LP (ID 828461) Starpower Communications, LLC dba RCN (ID 817208) ‘Anny CPN 16.36 Dear Seeretary Dorteh: Attached for filing in EB Docket No. 06-36, please find the Annual 47 CER. § 64.2009(e) CPNI Compliance Certifiate and accompanying statement of RCN Telecom Services (Lehigh) LLC, REN Telecom Services of Massachusetts, LLC, RCN Telecom Services (of Ilinois, LLC, RCN Telecom Services of Philadelphia, LLC, RCN Telecom Services of New ‘York, LP, and Starpower Communications, LLC d/b/a RCN (collectively, RCN") ther re questions regarding this ling, please contac the undersigned. Thank you for your assistance Sincerely, RCN intey B. Keath Executive Vice President, General Counsel & Corporate SecretaryCompliance EB Docket No, 06:36 Annual 64.2005(¢) CPNI Certification for Calendar Year 2015 Date filed: February 26,2016 CCettying Companies wit Form 499 Filer IDs: RN Telecom Services (Lehigh) LLC (ID 828462) RCN Telecom Services of Massachusetts, LLC (ormerly, RCN BeeoCom, LLC) ID 814387) RCN Telecom Services of Hinis, LLC (ID 820149) REN Telecom Services of Philadelphia, LUC ID 812061) REN Telecam Services of New York, LP (ID 828461) ‘Starpower Communications, LLC dla RCN (ID 817208) ‘Name of signatory: JeflteyB. Kramp “Title of signatory: Executive Viee President, General Counsel & Corporate Secretary |, efftey B. Kramp, cetfy that Iam an officer of RCN Telecom Services (Lehigh) LLC, RCN Telecom Services of Mastachusets, LLC, RCN Telecom Services of Minois, LLC, RCN Telecom Services of Philadelphia, LLC, RCN Telecom Services of New York, LP, and Starpower ‘Communications, LLC dla RCN (collectively, “RCN” othe “Companies”, and acting as an agent ofthe Companies, [have personal knowledge that RCN has established operating procedures that are ‘adequate to ensure complizce with the Commission's CPNL rues, See 47 CIR. § 64.2001 ef seq. Attached to this certffation isan accompanying statement explaining how the company’s procedires ensure tht the company isin compliance withthe requirements set forth in section {64.2001 e seq. ofthe Commission's rules, RCN has not taken any actions (proceedings instituted or petitions fled by «company st cither stale commissions, te cour system, ora the Commission) against data brokers inthe past Sea RCN has no information to report wth respect to the processes pretexters are using fo attempt {o access CPNI. Furtherme, RCN’s steps taken fo protect CPNI ae described in the accompanying statement RCN has not received any customer complaints concerning th unauthorized release of CPNI inthe past By: a ‘eieyB. Kamp Exective Viee President, General Counsel & Corporate SecretaryREN February 26,2016 Certificate to Accompany Annual 47 54.2009(¢) CPNI Certifi EB Dockst No, 06.36 RN submits this ecompanying statement o explain how the company's procedures ensue that the company isin compliance withthe substantive roquiement se forth in Section 64.2001 et seg. of the (Commission's ls, 1. Compliance wits § 64.2007, approval required for use of customer proprietary network information: Jn thos instances inwhich customer approvals roguired for use of CPNI, RCN obiais approval through orl andor writen nethods. RCN obtains opt-out approval as described in tem 2, below. RCN tloes nt curently wse CPNIfor any purpoce for which opin approval roguied under the ‘Cemisson’s les, wit th exception of per-al eptin approval as dseibed in item 2 below. The ‘customer's approval or dhayproval ous, disclose, ar peat access to customers CPNI obtained by RCN remains n effec untithe customer revakes or ims such approval or disapproval, Records of ‘ustomers* CPNT approvals are kept per RCN's stander operating procedure, which amount oa period fat east one (1) year 2. Compliance wit § 64.2008, notce required for use of customer proprietary network Information: roe tosoistng th castomers continuing opt-out approval for se of CPNI, RCN provides ‘wien notiteation ofthe customer's riht to reset so of, dscosur of apd acceso that custom's (CENL. Tho content of sh sotiton complies with the Commission's ales. RCN keeps records of hotfeation fore east one your. Opts notice re provided fo customer very you nd Coroners fe idven a minimum of hry 0) day to opcout bole they are presumed to have consented to use o their ‘CPNL For onetime use of CPNT an inbound and outbound customer telephone contacts forthe duration ‘ofthe cal only peal ptin), RCN's representatives obtain oral consent fom the customer pursuant to ‘customer servic sori th omplies with ho Commission's ules. 3. Compliance with § 64.2009, safeguards required for use of customer proprietary network: information: [RCN has system ia place by which the stats of» customers CPNI approval canbe clearly cxtablsed pie tthe use of CPN. Specifically, RON identifies al eastmers wh have opted-out of ‘tse oftheir CPNT by so noting on thei account ecrd inthe database supporting KCN's convergent voice, video, end data billig and eastomer eae solation management syste RCN then compare all miketng Hits against those customers ieatified as having opted-ot trough the company’s accom reords database. Personnel ar tnined ast when they are andar not thorized o use CPNI, and RCN bas a disciplinary proces in place for noacompliance. A record in ‘Compliance withthe Commrsion’s ules is kat fora minimum of on year of REN and its ait ‘marking camps tat us our customers’ CPNL and instances in which our customers" CPN Aisclosd or provided to, or accessed by, hil pate. | |RCN February 26,2016 Tadtion, RCN bain place and keeps records fra minimum of one your of review press eguding compliance with he ues for ouound marking smations, which requires sles personnel 10 ‘bian approval of any proposed outbound markecng request for customer approval 4. Compliance with § 642010, safeguards onthe disclosure of eustomer proprietary network information: RN hse pyscal arty, information technology, snd personnel measures in place to discover and protect gaint tempt in unauteried aces fo CPN. With the exception of commercial tosis eastomers tht have bot a dedicated account representative and a contract that pecically ‘dresses protection of CPM, customers ae asked 1 establish a pasword and provide answers to back- {ap security question that dot use eal available biographical information or account information, Customers who forget their password snd eanot provide the aniver to their back-up security questions to retrieve their pesoword ae required to be re-auentcted to establish w new password ard new answers to back-up serity questions. Passwords are required for a customer to obtain onlin acess to CPNI and pir to dsclonre othe customer of ell deal information ovr the telephone. Customers, ‘who do ot have a passwore may have RCN send call detail and other account information tthe Customers adress of recor. Customers requesting CPNT atone of RCN's retail locations mus presenta ‘lid photo ID matching the customer's account infomation, Inthe event a password, customer answer tos back-up security question, online asonnt adcess of cord is eased > changed, RCN immediately provides notice tothe cstomer atthe pre- exiting sddres of rovord va US Mail. Such atc informs th customer asf the nature ofthe change, ‘but doesnot revel the changed information ‘5, Compliance with § 642011, notification of castomer proprietary network information security breaches: RCN didnot experince any CPNT breaches during the reporting year. Notwithstanding, RCN ‘asin place procedares to tect reches and to noify law enforcement and usters, in compliance ‘withthe Commission's uly, shoulda breach occur. Inthe evento a reach, RCN has procedures in place to msistin a roared nfifentions to law enforcement and customers documenting the dat) of Aisovery and nffeation, desaleddasrption ofthe CPNT that was the subject ofthe Breach and he creumsances ofthe breach “When required in peviows yours, RCN hus maintained a physical and electronic reson ofthe olfations to ln enforcenint andthe customers, aswell ba more sostantve summary ofthe ‘reumstances and eubjoemate of th beach, All cords sre and eontinus to be maintained fora ‘nina of to (2) years, accordance withthe Comission’ sas.