Friday, July 20, 2012

What the heck is CPNI?

What the heck is CPNI?

CPNI stands for Customer Proprietary Network Information.  What is this, and should you be concerned about it?

From the Wikipedia page on CPNI:

Customer proprietary network information (CPNI) is the data collected by telecommunications companies about a consumer's telephone calls. It includes the time, date, duration and destination number of each call, the type of network a consumer subscribes to, and any other information that appears on the consumer's telephone bill.
Telemarketers working on behalf of telephone companies, attempting to either win back a customer or upsell a customer with more services, must ask the customer's consent before accessing the billing information or before using that information to offer an upsell or any change of services. Usually this is done at the beginning of a call from the telemarketer to the telephone subscriber.
I received a post card in the mail today from AT&T.   AT&T has great services but routinely decides it needs to screw the pooch, as I guess some VP in a glass tower somewhere has nothing else to do, other than piss off existing customers.   They want to use this data to market to us, and the government has said that we have the the theoretical right to opt-out of this marketing.  The key word here is, theoretical:
The U.S. Telecommunications Act of 1996 granted the Federal Communications Commission (FCC) authority to regulate how customer proprietary network information (CPNI) can be used and to enforce related consumer information privacy provisions. The rules in the 2007 FCC CPNI Order further restrict CPNI use and create new notification and reporting requirements. 
The rules in the 2007 CPNI Order include:-
  • limits the information which carriers may provide to third party marketing firms without first securing the affirmative consent of their customers
  • defines when and how customer service representatives may share call details
  • creates new notification and reporting obligations for carriers (including identity verification procedures)
Despite what Wikipedia says, AT&T is taking the position that your CPNI data can be used for marketing, and that you must opt out of this, not opt in with affirmative consent.  It seems in 2007, this "opt in" thing was seen as not enough fun for the telcoms, so President Bush gave the telcons a nice "thank you parting gift" before he left the White House:
Note that as long as an affiliate is "communications" related, the FCC has ruled that CPNI is under an opt-out approach (can be shared without your explicit permission). A phone company is permitted to sell all information on you, such as numbers you call, when you called them, where you were when you called them, or any other personally identifying information. CPNI would normally require a warrant for law enforcement agencies, but it can be freely sold to "communications" related companies. One can verify this by checking rule 64.2007(b)(1) and footnote 137 in the 2007 CPNI order. One can call up a phone company and opt out by requesting that they do not share CPNI information.
So, they are offering to let me "opt out" of allowing my CPNI data to be used for telemarketing purposes, and then offers three ways (none of which clearly work) to allow me to opt out of this "service."

The first method is a web site: which seems pretty straightforward, until it asks for your "account number".   Um, what is that, again?

They tell you it is "on your phone bill at the very top!"

So you download a .pdf copy of your phone bill after logging into and remembering your username and password, which of course is not your "account number".  There is an "account number" at the top of the bill, right after the word "account number" and has your phone number, plus seven additional digits, with spaces and dashes.

But, funny thing, the number that appears AFTER "account number" won't work when typed in.   For some reason, AT&T thinks that only the first 13 digits are the "account number" and the last four digits are not.   But they don't tell you this, of course.   Oh, and remove the spaces and dashes.  You should have known that, even if it wasn't written anywhere.

And when you call in, a bored AT&T call center person will castigate you for being so STUPID not to know this.  I mean, it is obvious on its face that the "account number" is just the first 13 digits after the word "account number" and the other four are used for God-Knows-What, right?  You idiot!

So, unless you know this "trick" the website won't work.  And you are prompted to call an operator at 1-800-288-2020.

And by the way, this is not the first time I have run into this "account number" gambit at AT&T.  It is not your phone number, but your phone number plus the next three digits displayed on your bill.  But not the next four.  Why do they do this?  To make you feel like an idiot, I guess.

So you call the 1-800 number and get put on hold and then talk to a foreign-voiced person.  The problem with this approach is that they immediately try to "sell" you on not opting-out.  "Don't you want to receive exciting new offers from AT&T which could save you money?" she says.

No, I do not.  The reason being, that whenever a telecommunications company tells me they want to "save me money" for some weird reason, I always end up spending more.   Funny how that works - telcom  giants do not have any vested interest in "saving you money" and most "savings" are in bogus "bundling" plans that get you to buy  more services, for a six-month discount.

So, in a thick foreign accent, she says that it is "all taken care of" - but you know, for some reason, I don't quite trust her.   Would you?

So I try the third option, calling their automated number - 1-800-315-8303.   Again, they want my "account number" and when I enter it, it says it is not valid.  I try my phone number.  Again, not valid.  I finally stumble across the combination of my phone number and the next three digits in the account number, without spaces and dashes, and it seems to take it.  It announces that my "request"  will be processed.

It is a classic case of the wear-you-down technique of marketing.  When they don't want you to do something - like disconnect a service or opt-out of an odious toolbar, they make it hard to do.   It is possible to do - so they comply with the letter of the law.  But if you didn't know the 13-digit trick on your "account number", you likely would get frustrated and give up.

Score:  AT&T: 1  You: 0

Should you opt out of the CPNI deal?   I am not sure it makes much of a difference.  But the way that AT&T alerted me to this (an easily lost or discarded post card covered with fine print) and the way they made it difficult to opt out in a straightforward manner, leads me to believe that they want people to not opt-out.   Clearly, selling your phone call data has got to be a pretty profitable gig for them, or they wouldn't make it so hard to figure out.

Other things, that AT&T wants me to do are not marketed to me in small grey postcards, hard to type URLs, indecipherable websites, or odd 1-800 numbers with unclear instructions as to what your "account number" exactly is.  When they want you to do something, like spend money, they make it as easy as falling in the lake.

If I want to get a new Smart Phone, there is no difficulty in doing so.  You go online and in a few clicks, one is shipped to your house, and you are upgraded to an expensive data and texting plan.

In a way, it reminds me of the conveyor belt at Caesar's Palace in Vegas.  It whisks you off the sidewalk on the strip and deep into the bowels of the casino, within seconds.  Getting back out again took a half an hour.  It is the slaughterhouse theory of marketing.

I am happy with AT&T services, generally (although today, they screwed up my call forwarding again, for some reason, and now I have to have it reset).  But I do not trust them very much.   Too much of this shenanigans makes me realize they are not on my side.

But then again, what telcom company is?   The idea that these are all happy-go-lucky companies that just want to help you out so you can have fun with your new smart phone, is idiotic.   The marketplace is a battlefield, and you are at constant war with these people.  They are the enemy.

Be vigilant!