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Annual 47 C.F.R. 64.2009(e) CPNI Certification EB oc!

et 06"#6

Marlene H. Dortch, Secretary Federal Communications Commission Office of the Secretary 445 12th Street, SW Washin ton, DC 2!554
"nnual #4.2!!$%e& C'() Certification for 2!14 co*erin the +rior calendar year 2!1, Date filed- 2.12.14 (ame of com+any co*ered /y this certification- 0rafton 1ele+hone Com+any Form 4$$ Filer )D- 2!1,#, (ame of si natory- Carolyn Susan "rnold 1itle of si natory- Cor+orate Secretary ), Carolyn Susan "rnold, certify that ) am an officer of the com+any named a/o*e, and actin as an a ent of the com+any, that ) ha*e +ersonal 3no4led e that the com+any has esta/lished o+eratin +rocedures that are ade5uate to ensure com+liance 4ith the Commission6s C'() rules. See 47 C.F.8. 9 #4.2!!1 et seq. "ttached to this certification is an accom+anyin statement e:+lainin ho4 the com+any6s +rocedures ensure that the com+any is in com+liance 4ith the re5uirements %includin those mandatin the ado+tion of C'() +rocedures, trainin , record3ee+in , and su+er*isory re*ie4& set forth in section #4.2!!1 et seq. of the Commission6s rules. 1he com+any has not ta3en any actions %i.e. +roceedin s instituted or +etitions filed /y a com+any at either state commissions, the court system, or at the Commission a ainst data /ro3ers& a ainst data /ro3ers in the +ast year. 1he com+any has not recei*ed any customer com+laints in the +ast year concernin the unauthori;ed release of C'(). 1he com+any re+resents and 4arrants that the a/o*e certification is consistent 4ith 47.C.F.8. 9 1.17 4hich re5uires truthful and accurate statements to the Commission. 1he com+any also ac3no4led es that false statements and misre+resentations to the Commission are +unisha/le under 1itle 12 of the <.S. Code and may su/=ect it to enforcement action. Si ned->> > >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Carolyn Susan "rnold Cor+orate Secretary 0rafton 1ele+hone Com+any 11$ ?. Main Street 0rafton, )llinois #2!,7@ #12.72#.,,11 susanaA tec.net "ttachment- "ccom+anyin Statement e:+lainin C'() +rocedures

Certification Statement
Fe/ruary 12, 2!14 0rafton 1ele+hone Com+any C'() O+eratin 'rocedures 0rafton 1ele+hone Com+any has +ro*ided trainin to e:istin em+loyees and 4ill +ro*ide trainin to all ne4 em+loyees on the +ro+er us and disclosure of %C'()&. 8ecords of the trainin material and documentation of the attendance is 3e+t on file. "ny em+loyee6s noncom+liance C'() +olicies 4ill /e re+orted and a++ro+riate disci+linary ste+s ta3en. C'() notification letters 4ere sent to all customers e:+lainin 4hat C'() is and as3ed customer to call office to set u+ a +ass4ord and challen e 5uestion. When customer calls, no C'() information is released 4ithout a +ass4ord. When a customer comes in.store, a *alid +hoto )D is re5uired /efore releasin C'() information. When customer6s C'()6s data re5uested /y +hone or in +erson, em+loyees *erify /y +rocedures noted in their C'() trainin manual. "fter a chan e or re5uest of C'() data has occurred, the customer is notified /y mail to address of record a notification of chan e and a lo is made in the /illin system. "ll ne4 customers are as3ed to esta/lish security information for C'(). 1he customer is also i*en the letter descri/in C'(). 0rafton 1ele+hone Com+any /illin com+any is also com+liant 4ith the C'() re ulations. )n the +ast year, no action ta3en a ainst data /ro3ers and no customer com+laints recei*ed concernin unauthori;ed release of C'().

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