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

et 06"#6

Commissions Secretary Marlene H. Dortch Office of the Secretary Federal Communications Commission 445 12th Street, S Suite ! "#$25 ashin%ton, DC 2&554
#nnual '4.2&&()e* C+,- Certification for 2&14 co.erin% the /rior calendar year 2&1$. Date filed0 2"12"14 ,ame of com/any co.ered 1y this certification0 2rafton !echnolo%ies, -nc. Form 4(( Filer -D0 322453 ,ame of si%natory0 Susan Hamilton !itle of si%natory0 4ice +resident -, Susan Hamilton, certify that - am an officer of the com/any named a1o.e, and actin% as an a%ent of the com/any, that - ha.e /ersonal 5no6led%e that the com/any has esta1lished o/eratin% /rocedures that are ade7uate to ensure com/liance 6ith the Commissions C+,- rules. See 48 C.F.9. : '4.2&&1 et seq. #ttached to this certification is an accom/anyin% statement e;/lainin% ho6 the com/anys /rocedures ensure that the com/any is in com/liance 6ith the re7uirements )includin% those mandatin% the ado/tion of C+,- /rocedures, trainin%, record5ee/in%, and su/er.isory re.ie6* set forth in section '4.2&&1 et seq. of the Commissions rules. !he com/any has not ta5en any actions )i.e., /roceedin%s instituted or /etitions filed 1y a com/any at either state commissions, the court system, or at the Commission a%ainst data 1ro5ers* a%ainst data 1ro5ers in the /ast year. !he com/any has not recei.ed any customer com/laints in the /ast year concernin% the unauthori<ed release of C+,-. !he com/any re/resents and 6arrants that the a1o.e certification is consistent 6ith 48. C.F.9. : 1.18 6hich re7uires truthful and accurate statements to the Commission. !he com/any also ac5no6led%es that false statements and misre/resentations to the Commission are /unisha1le under !itle 13 of the =.S. Code and may su1>ect it to enforcement action. Si%ned??????????????????????????? Susan Hamilton, 4ice +resident 2rafton !echnolo%ies, -nc. $&1 Commerce @l.d. Aersey.ille, -B '2&52C '13"'$("4341 #ttachment0 #ccom/anyin% Statement e;/lainin% C+,- /rocedures

Certification Statement
Fe1ruary 12, 2&14 2rafton !echnolo%ies, -nc. C+,- O/eratin% +rocedures 2rafton !echnolo%ies, -nc. )2!-* has /ro.ided trainin% to e;istin% em/loyees and 6ill /ro.ide trainin% to all ne6 em/loyees on the /ro/er us and disclosure of )C+,-*. 9ecords of the trainin% material and documentation of the attendance is 5e/t on file. #ny em/loyees noncom/liance of 2!-s C+,- /olicies 6ill 1e re/orted and a//ro/riate disci/linary ste/s ta5en. ,otification letters 6ere mailed to address of record to all customers e;/lainin% their ri%hts re%ardin% C+,-. Customers 6ere as5ed to contact office to esta1lish security information to /rotect their data. Customers that didnt res/ond to mailin% 6ere then contacted a%ain .ia a letter to address of record 6ith randomly selected security information for their account. Customers are allo6ed to chan%e security information after .erification of customer. hen customers C+,-s data is re7uested either 1y /hone or in /erson customer, em/loyees .erify 1y /rocedures noted in their C+,- trainin% manual. #fter a chan%e or re7uested of C+,- data as occurred, the customer is then notified 1y mailed to address of record a notification of chan%e, and then a lo% is made in 1illin% system. #ll ne6 customers are as5ed to esta1lish security information for C+,-. !he customer is also %i.en the letter descri1in% C+,-. 2!-s 1illin% com/any is also com/liant 6ith the C+,- re%ulations. -n the /ast year, no action ta5en a%ainst data 1ro5ers and no customer com/laints recei.ed concernin% unauthori<ed release of C+,-.