GTI Corporation

dba GTI Telecom

Annual4T C.F.R. S 64.2009(el CpNt Certification
EB Docket 06-36

Annual 6,1.2009(e) cPNl certification for 2015 covering calendar year 2oL4
Date

filecl: February 26,201.5

Name of comPany cclvered by this certification: GTI Corporatio n d/b/a GTI Telecorn
Form 499 Filer lD: 82:8800
Name of :signatory: lVlaria Olfrvia L. Clavio

Title of silgnatory: President

l, Maria Olivia L. Clavio, certifythat I am an officer of the company named above, and
acting as an agent of the cornpany, that I have personal knowledge that the company has
established operatirtg procedures that are adequate to ensure crompliance with the
Commission's CPNI rules. Sere 47 C.F.R. 5 64.2001 et seq.

Attached to this certification is an accompanying statement explaining how the

Company's procedures ensure that the company is in compliance with the requirements
(includin6l those martdating the adoption of CPNI procedures, training, recordkeeping, and
supervisory review) set forth in section 64.2001, et seq. of the Commission's rules.
Thre company' has not taken any actions (i.e., proceedings instituted or petitions filed
by a company at eitlrer state commissions, the court system, or at the Commission against
data brokers) against data bnokers during the past year.

Tl"re compan'y

has not received any customer complaints during the past year

concerning the unauthorized release of CPNI.

company'represents and warrants that the above certification is consistent with

47 C.F.R. 5 t.tl which requires truthful and accurate statements to the Commission. The
company also acknowledges that false statements and misrepresentatiorns to the Commission
are punislhable unden Title 1E of the U.S. Code and may subject it to enforcement action.
Tl"re

signed-

,.;^'L

Maria Olivlia L. Clavio

700 North Central Ave. Suite 205, Glendole, CA 921-03
Teleprhone 21-3.259,0500/0501 Fax 21-3.259.0502

www.olobemobile.us

GTI Corporration
dba GTI Telecom
Annual 47 C.F.R. 5 64.2009(e) CpNt Certification
EB Docket 06-36

Alttachmenrt 1: Statement Concerning Company procedures

General duty, training;, and di:;cipline.
GTI Corporation (the'"Company") advises all employees of their duty to safeguard CpNl. Employees
are advised that violations of the CPNI Policy will subject an employee to disciplinary action, up to and

including immediate tr:rmination of employment. The Company makes CpNl available to employees
only on a need-to-know basis.
Use of customer proprietary network information without customer approval (47 C.F.R. $ 6a.2005);
Approval nequired for use of customer proprietary network information (47 C,F.R. $ 6a.2007); Notice

required lior use of customer proprietary network information (47 C.F.R. $ 64.2008); Safeguards
required for use of cu:stomer proprietary network information (47 c.F.R. S 64.2009)

The Comprany does not use, disclose, or permit access to CPNI for marketing purposes exceplt as
permitted by Section 2!.22 of the Communications Act or regulations implementing Section 2ZZ of the
Communications Act. The Contpany does not disclose CPNI to third parties or permit third parties to
access or use CPNI, except as permitted by Section 222 of the Communications Act or regulations
impf ementing Section 222 of the Communications Act.
Safeguaids on the disclosure of customer proprietary network information (47 C.F.R. S 64.2010)
The Company does not operate any physicalstores, so does not provide any in-store access to CipNl.
The Company offers its, service ion-line, and does not provide any on-line access to CpNl without proper
customer-a uthentication.
Customers may access; their CFNI online and establish a password for future access only after they

have been authenticated wilthout using readily available biographical information or account
information. After initial auttrentication, customers may only access CpNl online by providing a
password that is not prompted by a request for readily available biographical iinformation or account
informaticrn. lf a customer cannot provide the correct password, the customer must be
reauthentiicated beforr: being provided with a password.
The Company does not provide any telephone access to call detail information based on customer-

initiated telephone contact. Customers requesting call detail information by telephone will be
provided with call detail information only by sending it to the customer's address of record. lf a
customer is able to provide call detail information to the Company during a customer-irritiated call
without thre Company's assistance, the Company will discuss the call detail information provided by
the custonrer.

700 North Centrol Ave. Suite 205, Glendale, CA 92L03

Telepthone 2L3.259.0500/050i. Fax 213.259.0502

www.qlobemobile.us

GTI Corporation
dba GTI Telecom
The Company's procedures requires it to notify customers immediately by email to the customer,s
email address of record or by mail to the customer's postal address of record ,of any changes to a lost
or forgotten customer password, online account information, or address of record. This notice does
not reveal the changed information and is sent to the existing address, not to an address that has
been changed. To date, the Company has not had to notify a customer on account of changes to the
above categories of information.

Notification of custonrer proprietary information security breaches (47 c.F.R. g 64.2011)

The Company's operalting procedures require notification of relevant law enforcement agencies and
customers in accordance with FCC rules in the event of a breach of CPNI. The Company maintains
records ol'any breach,es discovered, notifications made to law enforcement, and notifications made
to customers. These records include, where available, dates of discovery and notification, a detailed
description of the CPNI that was the subject of the breach, and the circumstances of the breach. The
Company retains these records for 2 years.

700 North Central Ave. Suite 205, Glendale, CA 92103

Telephone 2L3.259.0500/0501 Fqx 273.259.0502

www.globemobile.us