Communications Assistance for Law Enforcement Act - CALEA Policy and Law Enforcement Request Method of Procedure
Introduction
Communications Assistance for Law Enforcement Act (“CALEA”) is intended to preserve the ability of law enforcement agencies to conduct electronic surveillance while protecting the privacy of information outside the scope of the investigation. We will also require compliance with our Customer Protected Network Information (“CPNI”) Policy when responding to a request made under this CALEA Policy. HolstonConnect is a VoIP service provider and internet service provider. As the entity facing the end user subscriber HolstonConnect is the entity that can best verify the identity of the end user subscriber and furthermore is the best source for records relating to both the telephone number in use and the end user subscriber.
Call Detail Records (“CDRs”) and IP Address Information
Typically, CDRs or IP Address information must be pursued directly from the entity facing the end user/subscriber. To the extent, we have CDRs they are readily accessible for approximately 45 days. Compliance with our CPNI Policy will be required when responding to any request for CDRs or IP Address information. If, after your review of our CPNI guidelines, you believe HolstonConnect is the appropriate source for providing records, please contact our CPNI Officer or CALEA Officer.
Civil Subpoenas
Subpoenas issued in matters of civil litigation in which HolstonConnect is a non-party must be served in accordance with our Civil Subpoena Guidelines, which also provides for methods of service, applicable fees, and requirement for a protective order when seeking records.
Civil Subpoena Guidelines
Civil litigants will generally want to issue an initial request to HolstonConnect for the purpose of identifying our customer and thereafter, pursue records through a legal subpoena directly to that customer. HolstonConnect will initially and conditionally provide an estimate of the HolstonConnect CDR Processing Fee applicable to all requests for records.
Protective Order
Where HolstonConnect is required to provide/produce records, such production will only occur pursuant to a protective order issued by the court having jurisdiction in the case. Such orders will be limited in both access and use, specifically for purposes of litigation and appeal.
Trace Back Exception
Call Trace Back is the exceptional, isolated circumstance in which HolstonConnect CDRs may contain some unique information. Call Trace Back is the telecom industry’s process of recreating the path of a telephone call in reverse (i.e., going from the called party’s service provider to one or more intermediate providers, and ultimately to the calling party’s service provider). If the calling name/number is spoofed/blocked that manipulation occurs prior to the
network and therefore our records reflect only the spoofed/blocked details; the network-level details of a CDR will remain unaffected. By recreating the call path, the originating network can be determined, and thereby, the actual calling number and end user subscriber’s identity. Specific details will be required, by way of example “the call from NPA-NXX-1234 to NPA-NXX-5678 on MM/DD/YYYY at 12:23 pm ET for 45 seconds”. Allow at least five (5) business days for a Call Trace Back request for a call made within the prior forty-five (45) days. Call Trace Back requests for calls made more than forty-five (45) days prior will typically require archive retrieval and must allow at least fifteen (15) business days for processing and an ICB processing fee may apply. Fees may also apply for voluminous requests. HolstonConnect shall cooperate with Call Trace Back requests as may be applicable and in compliance with our STIR/SHAKEN and Robocall Mitigation Policy.
Submitting a Formal Lawful Request for Information
All requests must include, at a minimum, the following information:
1. Full contact information with Agency name, physical address, E-mail address and direct contact telephone number.
2. Target telephone number(s) in the XXX-XXX-XXXX format or target IP Address(es) in the XXX.XXX.XXX.XXX format.
3. Specific dates (To/From in MM/DD/YYYY format) for which information is being requested.
4. Brief description of the matter.
E-mail the request to CALEA_Request@HolstonElectric.com with a copy of your subpoena, court order, search warrant, or other formal legal documentation. If you have multiple requests, please submit only one legal document per E-mail to ensure individual tickets are created in our system. For requests involving ten (10) or more records, please attach an Excel, or text file listing target telephone numbers or IP addresses in the format described above, one (1) record per line.
Official Address for Service of Process
Name: Jeffery Gunter
Title: Director of Network Administration Holston Electric Cooperative \ HolstonConnect, LLC
Address 1: P.O. Box 190
Address 2: 1200 W. Main St., Rogersville, TN 37857
Email: JGunter@HolstonElectric.com
Faxed legal demands will NOT be processed. Submit Legal Demands via E-mail to CALEA_Request@HolstonElectric.com. We do NOT consent to fax transmission.
Normal Hours of Availability
Our normal business hours are Monday through Friday, 8:00 am to 5:00 pm Eastern Time.
Exigent Formal Lawful Requests
If you have a declared exigent circumstance as established by your agency’s guidelines, send an E-mail to CALEA_Request@HolstonElectric.com with the word “Exigent” in the E-mail subject line.
Exigent Requests Outside Normal Business Hours
If you have a declared exigent circumstance as established by your agency’s guidelines, outside of our normal business hours contact: JGunter@HolstonElectric.com
Written requests will be required; no action will be taken based on a verbal request.
Intercept Arrangements
HolstonConnect is generally the optimal point for intercept arrangements as we carry all traffic relating to a telephone number across our network but it may be necessary to engage our 3rd Party Voice provider... If you believe that we the appropriate location for your register/intercept, please first contact JGunter@HolstonElectric.com for assistance. Upon receipt of an order or warrant directing HolstonConnect to establish an intercept arrangement and following verification of the Submitting Agency’s understanding of the limitations as described herein, HolstonConnect will notify applicable third-party vendors, who will then contact the Submitting Agency directly to arrange for implementation, where applicable. The applicable third-party vendor is NOT authorized to accept service of a Legal Demand on behalf of HolstonConnect.
Note: HolstonConnect is a VoIP Service Provider and not a wireless carrier therefore there is no pingable, GPS, or cell site location information native to our Service Provider customers’ numbers and therefore not available from us.
HolstonConnect reserves the right to modify this Policy at any time. We will notify you of any material changes via electronic or other means permitted by law, including by posting it on our HolstonConnect website. Concerns regarding this Policy should be directed to the HolstonConnect’s Jeffery Gunter at JGunter@HolstonElectric.com.
Version 1.0, Effective June 15, 2022