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The policy discloses that CPNI (telecommunications usage data including call records, location, and billing information) is governed by federal law and that Verizon may seek consent to use CPNI to market services beyond those a customer already has, with an opt-out available.
This analysis describes what Verizon's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that CPNI is subject to federal Communications Act requirements and that customers can limit its use for marketing beyond existing services, an operationally significant right for telecommunications customers that is governed by FCC rules rather than general consumer privacy law.
The agreement establishes that Verizon's use of call records, location, and billing information for telecommunications services is governed by federal CPNI rules. You can limit the use of your CPNI for marketing purposes by calling 1-888-567-8688 or through the opt-out mechanism described in the policy.
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"Customer Proprietary Network Information (or CPNI) is information that relates to the type, quantity, destination, technical configuration, location, amount of use and related billing information of your telecommunications or interconnected Voice over Internet Protocol (VoIP) services. Federal law governs our use and disclosure of CPNI. Verizon may seek consent to market services to you that are different from the ones you have. You can limit the use and disclosure of Customer Proprietary Network Information and certain credit information in response to such requests.Excerpt from Verizon's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision directly engages the Communications Act's CPNI framework, enforced by the Federal Communications Commission. FCC rules specify consent requirements, data security obligations, and restrictions on CPNI use for marketing purposes. The FCC's 2024 data breach notification rules for telecommunications carriers (effective 2024) also apply to CPNI-covered data. The intersection of CPNI with state privacy laws such as CCPA creates overlapping compliance obligations, as state laws may apply to data that falls outside strict CPNI definitions but is collected in the same context. (2) GOVERNANCE EXPOSURE: Medium. Verizon is a common carrier subject to mandatory FCC CPNI compliance. The primary governance exposure relates to whether CPNI marketing consent mechanisms satisfy current FCC rules, and whether the integration of CPNI with broader data uses described elsewhere in the policy (such as Custom Experience Plus, which expressly includes CPNI) is adequately disclosed and consented to under FCC requirements. (3) JURISDICTION FLAGS: CPNI obligations are federal and apply uniformly to telecommunications carriers in the United States. The Custom Experience Plus program's stated inclusion of CPNI data requires opt-in consent, which the policy correctly identifies. State laws may impose additional requirements on telecommunications data beyond CPNI's federal floor, particularly in California. (4) CONTRACT AND VENDOR IMPLICATIONS: Service providers who receive CPNI data from Verizon are subject to FCC requirements as well as Verizon's contractual restrictions. Legal teams should confirm that vendor agreements for CPNI-processing services include FCC-compliant data handling provisions and breach notification obligations. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that CPNI opt-out mechanisms are operationally current and that the integration of CPNI data into programs such as Custom Experience Plus, which require opt-in, is accurately implemented. The FCC's enhanced data breach notification requirements should be evaluated against current incident response procedures for CPNI-covered data.
This provision establishes that CPNI is subject to federal Communications Act requirements and that customers can limit its use for marketing beyond existing services, an operationally significant right for telecommunications customers that is governed by FCC rules rather than general consumer privacy law.
The agreement establishes that Verizon's use of call records, location, and billing information for telecommunications services is governed by federal CPNI rules. You can limit the use of your CPNI for marketing purposes by calling 1-888-567-8688 or through the opt-out mechanism described in the policy.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Verizon.