3. NHTC Informs Customers Regarding How Information Is Used.
4. NHTC Gives Customers Opportunities To Control Access to Information.
NHTC is committed to providing customers with opportunities to control how NHTC uses customer information about them. For example, customers may inform us of which telephone listings they want to include in our directories and in directory assistance and may also choose to have a non-published number, or a nonlisted number, or to exclude your address from your listing. Customers in areas where Caller ID services are available have the ability to block the display of their phone numbers and names. (Note that Caller ID blocking does not prevent the transmission of your phone number when you dial certain business numbers, including 911, or 800, 888, 877, and 900 numbers.) Further, customers can express a preference not to be called for marketing purposes (please see Section III, below, for more information on NHTC’s “Do Not Call” policy). Customers may also opt out of our direct mailings and other service marketing programs. (Please see Section II, below, for NHTC’s policy on the use of “Customer Proprietary Network Information”). A customer may indicate
a change in such preferences at any time by contacting NHTC customer service.
We do use individual customer information internally for planning purposes – so that we can, for example, develop, test and market new products and services that meet the needs of our customers. Ordinarily, such information is combined into aggregations that do not include individual customer identities. Under certain circumstances, we are required by law to disclose the aggregated information to other companies, but in such cases customer identities are not included.
5. NHTC Enables Customers To Control How NHTC Discloses Individual Information.
Ordinarily, NHTC will only share individual customer information with persons or entities outside the company to assist us in the provision of services to which the customer subscribes, or as required by law or to protect the safety of customers, employees or property. We do not use third-party marketers, nor do we share access to individual customer information derived from the provision of NHTC telecommunications services with other companies interested in marketing other services to our customers – and we would not do so without the consent of the customer. NHTC is committed to ensuring that customer information is not used without the knowledge and permission of our customers.
However, there are exceptions to our general practice. For example, unless you request otherwise, we may share certain personal or non-personal information with our affiliated companies with whom we have established business relationships. In addition, if NHTC enters into a merger, acquisition, or sale of all or a portion of its assets, a customer’s personally identifiable information will, in most instances, be transferred as a part of the transaction, subject to required notices to affected customers. In addition, we may, where permitted by law, provide information to credit bureaus, or provide information and/or sell receivables to collection agencies, to obtain payment for NHTC billed products and services. We are also required by law to provide billing name and address information to a customer’s long distance carrier and other telephone companies to allow them to bill for telecommunications services. (By law, customers with non-published or unlisted service have the right not to have their billing name and address disclosed when they make a calling card call or
accept a collect or a third party call. However, if they do restrict disclosure, they will be unable to make calling card calls or accept collect and third party calls.) Similarly, we are required to provide directory publishers with subscriber listing information – name, address and phone number, and for yellow page advertisers, primary advertising classification – for purposes of publishing and delivering
directories. In addition, under certain circumstances, we may share customer information with other carriers or with law enforcement, for example, to prevent and investigate fraud or other unlawful use of communications services.
6. All NHTC Employees Are Responsible For Safeguarding Customer Communications and Information.
We never tamper with, intrude upon or disclose the existence or contents of any communication or transmission, except as required by law or the proper management of our network. Access to databases containing customer information is limited to employees who need it to perform their jobs – and they follow strict guidelines when handling that information. We use safeguards to increase data accuracy and to identify and authenticate the sources of customer information. We use locks and physical security measures, sign-on and password control procedures, and internal auditing techniques to protect against unauthorized use of terminals and entry into our data systems. NHTC requires that records be safeguarded from loss, theft, unauthorized disclosure, and accidental destruction.
In addition, sensitive, confidential, or proprietary records are protected and maintained in a secure environment. It is our policy to destroy records containing sensitive, confidential, or proprietary information in a secure manner. Hard copy confidential, proprietary, or sensitive documents are made unreadable before disposition or recycling, and electronic media must be destroyed using methods that prevent access to information stored in that type of media. Just as employees would report stolen property, missing records and suspicious incidents involving records are referred to NHTC Management. We encourage our employees to be proactive in implementing and enforcing
NHTC’s privacy policies. If employees become aware of practices that raise privacy or security concerns, they are required to report them to their supervisors.
NHTC’s regulatory department is responsible for ensuring that all NHTC business units and their employees comply with privacy laws and regulations. NHTC also requires any consultants, suppliers and contractors that may come into contact with customer proprietary information to observe these privacy rules with respect to any of our customers’ individual customer information. They must abide by these principles when conducting work for us, and they will be held accountable for their actions.
7. NHTC Takes Special Care to Protect the Safety and Privacy of Young People Using Its Services.
NHTC does not knowingly collect information about children. NHTC believes that children should get their parents’ consent before giving out any personal information. NHTC encourages parents and legal guardians to participate in their child’s experience using NHTC’s services. Children should always ask a parent for permission before sending personal information to NHTC.
8. NHTC Complies with All Applicable Privacy Laws and Regulations Wherever NHTC Does Business.
Customer and policymaker perceptions of privacy have changed over time and will continue to do so. Changes in technology can also alter what is appropriate in protecting privacy. Laws may change accordingly. We regularly examine – and update as necessary –NHTC’s privacy policies and internal procedures to ensure compliance with applicable law and evolving technology. NHTC also will monitor customer needs and expectations. NHTC will work with policymakers and consumers to ensure that we continue to safeguard privacy, giving customers choices, flexibility and control. NHTC considers privacy laws and regulations to be the minimum standards to which we will adhere in protecting privacy. In addition to complying with the law, NHTC will adhere to its internal privacy policies and procedures wherever we do business.
9. NHTC Gives an Authorized Gov’t Agency Access to Customer Information Only Upon Valid Request.
NHTC may release customer information in response to requests from governmental agencies, including law enforcement and national security agencies, in accordance with federal statutory requirements or pursuant to court order. Before releasing any customer information, NHTC will ensure that the underlying governmental request satisfies all procedural and substantive legal requirements and is otherwise proper. For example, NHTC will ensure that any court orders are valid, properly issued, and legally enforceable. Except as required by law or with the approval of the customer, NHTC will not release any customer information in response to subpoenas or similar requests issued by private parties. Further, NHTC will be diligent in authenticating the validity of any “governmental” request to ensure that the request actually originates from an authorized government agency.
10. NHTC Uses Customer Proprietary Network Information (CPNI) In Accordance with the Law.
NHTC wants you to understand your rights to restrict the use of, disclosure of and access to your Customer Proprietary Network Information, or CPNI. You have a right and NHTC has a duty, under federal law, to protect the confidentiality of your Customer Proprietary Network Information.