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CPNI – The Gold Mine under LECs

We are presenting a joint webcast on May 12th at 2:00 pm E.S.T., with Telcom Consulting Associates (TCA) on CPNI: What is it and how to use it to increase sales?  Be on the lookout for more information. 

Karen Twenhafel, Regulatory Consultant for TCA, has provided the following brief educational background on CPNI.  Please remember that this is intended to be a general overview and should not be considered anything more than that. 

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Afterthought…Lost Wheelbarrow…Reindeer Queen.  What do these phrases have in common?  They are names of U.S. gold mines. 

CPNI is the unusual name for a gold mine that most LECs are sitting on, but don’t know it.   

Customer Proprietary Network Information (CPNI) is data specific to individual customers generated when customers make calls.  CPNI can include such things as the numbers your customers call, the percentage of interstate to intrastate calls, and (with a little detective work) your customers’ ISP. CPNI does not include subscriber list information or any customer information where you cannot identify which customer produced which data.   So by mining CPNI generated every day, you can have access to information that will make your marketing campaigns more focused and effective. 

LECs that have used CPNI in marketing plans report a dramatic increase in take rates.  One LEC, after using CPNI to determine the pricing and components of various package bundles, reports a 35% take rate.  One year earlier, the LEC had marketed similar bundles without the benefit of CPNI.  The take rate?  Seven percent.  Other LECs use CPNI to help in determining future services and focus groups.  One has even used CPNI to prioritize network upgrades.  In short, CPNI offers a rich vein that LECs may use to hone the competitive edge. 

As with most tools in a regulated industry, using CPNI requires compliance with rules.  LECs have a duty to notify customers prior to using CPNI, allow customers to restrict the usage of their specific information and generally comply with various regulations issued by the FCC and (possibly) state commissions.  While at first glance, these rules seem like an insurmountable mountain, with a bit of effort, the rules quickly become a molehill. 

In simplest terms, the regulations are easy to summarize.  When using CPNI for marketing purposes, a LEC must first provide notice to its customers and allow customers the chance to either say “OK, you may use my CPNI” or “No, please do not use my CPNI.”  Of course, no regulations are that easy, but a LEC that takes the time to understand and comply with the CPNI regulations will find great rewards. 

The type of approval or disapproval your customers give you depends on what you want to do with CPNI.  If you want to use CPNI to market communications-related services, including Internet access, then you only need to give your customers a chance to opt-out, or say “No.”  If a customer has not explicitly told you “No,” you are free to use that customer’s CPNI for marketing purposes.  If you want to market non-communications-related services, like a security system, then your customers must opt-in to the process by specifically saying, “Yes, you may use my CPNI.”  Opt-in approval is much more difficult for a LEC to obtain due to the explicit nature of the approval.  As opposed to opt-out approval (where a customer’s approval is assumed if you do not hear from the customer), a LEC can never assume that a customer is opting-in. 

Finally, the regulations do allow, under very precise circumstances, a LEC to use CPNI for marketing purposes without approval from the customer.  If you are marketing upgrades to a service that your customer currently subscribes to, then you may use that customer’s CPNI without approval.  For example, a customer who subscribes to your long distance service calls in to discuss her bill.  The CSR may use the customer’s CPNI to upsell a different calling plan.  The customer’s CPNI may be used, even if the customer has opted-out.  However, if the CSR attempts to sell the customer Internet access service, then the CSR has crossed the line and your LEC has broken the CPNI rules.   

Here is a cheat sheet that should get you started. 

Business Activity

Use of CPNI

Typical required activities to service a customer (i.e., billing, emergency call location, etc.)

No approval required

Customer-initiated calls regarding marketing

Oral opt-in approval required; customer approval valid only for duration of call

Marketing upgrades to services which the customer currently subscribes; Includes disclosure to affiliates or joint venture partners

No approval required

Marketing communication services to which the customer does not currently subscribe; Includes disclosure to affiliates or joint venture partners

Opt-out approval required

Marketing non-communication services; Includes disclosure to affiliates or joint venture partners

Opt-in approval required

Again, the CPNI regulations place additional requirements on a LEC and seem daunting when first viewed.  While complex, the regulations are manageable and the rich vein of gold struck when using CPNI, is in far excess of any effort needed to mine it.

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