Professional Documents
Culture Documents
I, William B. Risley, certify that I am an officer of the company named above, and acting as an
agent of the company, that I have personal knowledge that the company has established
operating procedures that are adequate to ensure compliance with the Commission’s CPNI
rules.
The company has not taken any actions (proceedings instituted or petitions filed by a company
at either state commissions, the court system, or at the Commission against data brokers)
against data brokers in the past year. I understand that Companies must report on any
information that they have with respect to the processes pretexters are using to attempt to
access CPNI, and what steps companies are taking to protect CPNI.
The company has not received any customer complaints in the past year concerning the
unauthorized release of CPNI. There have been no instances of improper disclosure to
individuals not authorized to receive the information, or instances of improper access to online
information by individuals not authorized to view the information.
IPscience, LLC follows the procedures and requirements of its partner providers
(CommPartners Network Services, LLC, and Qwest Communications, Inc.) to assure that clients
are made aware of the specific use of CPNI and provide affirmative and specific authorization
for the use of CPNI. In every instance requiring the use of CPNI the responsible individual from
the client must give specific permission by signature in a Letter of Agency (LOA) to authorize
the release and exchange of client information. In each instance the procedure and LOA
includes specific dates and periods of authorization for the exchange of the information. In this
way the company provides and receives information only as permitted by the client and in a
manner consistent with the procedures of the partner telecommunication carriers. Confidentiality
is strictly maintained since the information is for the private use of the company and its partners.
Records containing CPNI are kept under lock and key in the company’s files or in password-
protected electronic formats.