ITS TELECOMMUNICATIONS SYSTEMS, INC. .0.Box397, Indiantown, FL34986 77-597.2111 Annual 47 CER, § 64,2005 erties EB Docket 06.36 ‘Anns 64.2006) CPNI Cenifston for 2015 Date id: February 26, 2016 sme of Compiny Covered byt fon 48 Filer, TTS Tlecommunications Systems ne, si1040 [Name of signatory: Bruce A. Russell Title of signatory: Vie Presiden/CFO J, Bruce Russel, entity tht Tam an officer ofthe company named above (“Company”), ‘nd acting as an agent ofthe Company, tat Ihave personal knowledge tha the company has ‘stablished operating procedures thal are adequate to ensure compliance withthe Commission's CPNT rules. Sev47 CER. § 64.2001 ef seg Altached to this cetcalion is an accompanying statement explsining how the Company's procedure ensure tha the company isn compliance wih he requirements (Gocluding those mandating the adoption of CPNI procedures, vaining, recordkeeping, and supervisory review) set forth in setion 64,2001 et so. ofthe Commission's rules. “The Company has not taken any ations (proceedings institued or petitions filed by a company af either state commissions, the cour system, o atthe Commision asinst data broker) sysinst data brokers in the past yest. ‘The Company has nt recsived any 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 CER. $1.17, wlach requires truhfal and accurate statements tothe Commission. The Company also acknowledges that false statements and misrepresenttios othe Commission are punishable under Til 18 ofthe US. Code and may subject it to enforeement ation, Simned: P~ Prd} Bruce A-Rusell, Vite PresdendCFO ‘Attachment; Accompanying Statement explining CPNI proceduresITS TELECOMMUNICATIONS SYSTEMS, INC. 499 Filer ID 811040 0. Box 397, Indiantown, FL 34956 772-597-2111 2015 ANNUAL STATEMENT OF FCC CPNI RULE COMPLIANCE, February 25, 2016 This statement accompanies the Company's 2015 Customer Proprietary Network Information CCPNT) Cenifcation, as required by Section 64.2009(e) of the Federal Communications Commission's (“FCC's rales, forthe purpose of expiining how the operating procedures ofthe Company ensure compliance with Pan 64, Subpart U of the FCC's rules. Sev 47 CER § (642001 ese. Al subsequomt references to rule Sections refer to rales under Part 64, Subpart U unless indicaed otherwise, ‘As of this date, the Company has not used nor plans o use CPNI for marketing. For marketing ‘purposes, the Company uses customer billing name and address andlor telephone number ‘without any disaggregation or refinement based on CPNT. Identification of CPNI ‘Tae Company has established procedures and trained employees having acess fo, or oecasion to se customer daa, to identify what customer information is CPNI consistent with the definition ‘ofCPNT under the Section 64 2003(g) and Sesion 222(9(1) ofthe Communications Act of 1934 asamended (47 USC. § 222(0(1), 2 Idntifcation of Services Affected by CPNI Rules ‘The Company has established procedures and trained employees to recognize the different types of telecommunications and non-elecommunications services that affect how the Company uses ONL 3. Mlenticaton of Permissible Uses of CPNI without Customer Authorization ‘The Company ha established procedures and trained employees having acess to, or ocasion 10 ‘ue CPNI, to identify uses of CPNI not requiring customer authorization under Section 4.2008. 4. Hdentification of Uses of CPNI Requiring Customer Authorization ‘The Company has established procedures and trained employees having acces 0, or occasion 10 ‘us: CPNI, to idemity uses of CPNI requiring customer authorization under Section 642007 5 Customer Notification and Authorization Process The Company does not use CPNI for marketing and thus, at this time has not provided notice rezarding Opt-Out. Prior to any planned use of CPNI for marketing, the Company will initiate ‘he ntifieation and Opt-Out process, The Company does not provide CPNI io other parties and thas has not used the opt-in approval process. ‘The Company has trained employees regarding prohibition on use of CPNI for marketing. Prir to initiation of any program for use of CPNI for ‘marketing, the Company wil rain employees witha need ander esponsibility for obaiing1S Telecomsmuniations Systems, ne Ferme 25,2016, customer authorization to se CPNI for marking purpose, regarding the notice and approval equirements under Section 64.2008 6 Record of Customer CPNI Approval/Now-Approval [A such time ss Company may inital use of CPNI fr marketing with corresponding launch of ification and Opt-Out process, the Company will develop and vilize a sysiem fr maintaining, realy accessible record of whether and how a customer has responded to Opt-Out approval as required by Section 6.2009(8). 7. Procedures Protecting Against Disclosure of CPNI ‘The Company has implemented procedures for compliance with new Section 64,2010 including, ‘bt not imited tothe following Authestication of customers before disclosing CPNI on customeriitited telephone ‘contacts or business office visits. ‘The Company has implemented procedures 1o notify customers of account changes. & Actions Taken Against Data Brokers and Responses to Customer Complaints Pursuant to Section 64.2009, the Company makes the following explanation of any actions taken znst data brokers and a summary ofall eustome complaints received i the past year oncering the unauthorized release of CPN ‘Notapplicable- No ations taken agninstdta-brkers, No customer complains recived 9. Disciplinary Process ‘The Company has in place an express disciplinary process to address any unauthorized use of CCPNI where the circumstances indicate authorization is equi under Section 4.200%). 10. Supervisory Review Process for Outbound Marketing Before undertaking to use CPNI for outbound marketing purpscs, the Company will establish a supervisory review process lo ensure eomplance with Section 64.2000(4) of the FCC's Part 64, Subpart UCPNI rules. Procedures for Notifying Law Enforcement of CPNI Security Breaches “The Company has adopted procedures to comply with Section 64.2011 for notifying law ‘enforcement of CPNI security breaches, together with related recordkeeping and deferred notification to customers