Description of Express Dial Internet (dba KWISP) procedures to insure protection of CPNI

Updated 2/26/16

Introduction
KWISP currently uses streamlined CPNI procedures due to the following factors:

We have less than 1000 broadband customers

We have less than 50 voice customers
We personally know and recognize most of our customers
All CPNI is handled by one person, the Owner
Our prices are flat rate, so no usage information appears on customer bills
We do not share customer data with affiliates or third parties except as required by law

These procedures will be re-evaluated if any of these factors change. For example, if employees are
added who have access to CPNI. Or if customer count increases to the point where it makes sense to
assign every customer a PIN number.
Customer Identification
As noted above, we personally know most of our customers. But sometimes family members or
computer technicians may call on their behalf. If someone other than the account holder is requesting
customer information or making changes to the account, we require that the account holder provide us
authorization. If we do not personally recognize the customer, and they are not calling from the phone
number on file, we ask that they call from their home phone, or provide identifying information like a
recent invoice number.
Call Detail Records
CDRs contain usage information like called and calling numbers, dates, times, and durations and are
therefore CPNI. All our voice customers have unlimited domestic calling, the only time they would be
billed based on usage would be international calls, 411 calls, or rogue 911 calls. As a result, we have
never had a customer request CDR information.
If we do receive a CDR request, and the customer has a voicemail PIN, he/she can access the
information directly at the voicemail web portal. If not, we would email the report to the email address
on file for the account, or mail it to the address on file.
Internet Usage
In light of the recent Open Internet Order, we are unclear what broadband information should be
considered CPNI, if any. We only have records of how much bandwidth is used, not what websites
customers visit, so we could not disclose this information even if requested. We do occasionally access

bandwidth usage records as part of technical support and troubleshooting, for example if a customer
calls about slow speeds. If the customer asks what is using so much bandwidth, there are tools that
allow IP addresses to be identified in real time (not history). This information will only be shared with
the account holder, unless they specifically authorize us to work with someone else like a computer
technician or an application provider.
Use of Customer Data for Marketing
It is our policy not to use any customer information for marketing purposes.
Sharing Customer Information with Third Parties
It is our policy not to share any customer information with affiliates or third parties, even if doing so
would be legal. We do not sell or share customer lists. We do not capture or attempt to monetize
clickstream data or customer calling data.
Requests from Law Enforcement
If presented with a valid subpoena, court order, or national security letter, we will provide the
information requested while making a good faith effort not to disclose additional information. If there is
doubt as to the validity of the request or the identity of the persons purporting to be law enforcement,
we will consult the local police, FBI office, and/or legal counsel.
Our DMCA policy does not allow disclosure of any customer information, CPNI or otherwise, in response
to a notice of claimed infringement. Customers will be identified only in response to a valid subpoena or
court order.
Exceptions
Any unclear situations will require escalation to the Owner. Currently the Owner is the only person with
access to CPNI, so no escalation is required.
Hypothetically, a LEA might request information in a life-or-death situation which cannot wait for a court
order. (For example, a hostage crisis or terror threat.) This is extremely unlikely, but would be
evaluated by the Owner on a case-by-case basis. No such situation has occurred to date.
Complaints
We have never received a complaint about misuse of CPNI, and would be surprised if this happened, so
no procedures have been developed to handle CPNI complaints. In this unlikely event, we would consult
the FCC rules and act accordingly.