----- Original Message ----- 
From: "Matt Liotta" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>
Cc: "WISPA General List" <[email protected]>
Sent: Friday, April 27, 2007 4:03 PM
Subject: [WISPA] Re: CALEA


> Getting the data for the LEA is just one part of compliance. What about
> the more practical issues?
>
> CALEA requires:
> Establishment of policies and procedures for supervision and control of
> officers and employees

Who's got a coupel days to write legalese documents that detail everyting
they wanna know?

> Designating a 24/7/265 POC for the LEA

This means that no one or two man WISP can be compliant, unless you hire an
answering service, and have people on contact, or else have two of you on
duty 365 days a year, 12 hours a day.    One man can't do it himself.

> Validating legal authorization for the ELSUR

What's ELSUR?   I thought I'd managed to uncover all the acronyms already..
Guess not.

> Maintaining secure and accurate records

A summary of all the records you have to maintain would be helpful.

> Reporting any CALEA security breaches



>
> AND... filling with the FCC how you are going to do the above.
>
> Not implementing the policies and procedures may result in legal
liability.
>
> Assuming you have all that is needed to be compliant how do you actually
> comply with an order? You are going to at least need to collect the
> following information:
> Telephone number/circuit ID
> Start date/time
> Officer presenting order
> Judge issuing order
> Type of ELSUR
> Supervising carrier personnel
> Certification of “senior official...”
> Subscriber name
> Date/time order served
> Court issuing order
> Court docket/file number
> Law enforcement officers authorized to receive info
> LEA contact numbers
> Carrier employees involved
>
> And what about the warrant's validity? CALEA requires the carrier to
> determine the following:
> Does the Court have jurisdiction over Carrier?
> Does the Court Order provide for Technical Assistance?
> Has the Court provided for compensation?
> If problems arise, how does the carrier address the issues –
> inside/outside counsel, Service Bureau, etc
>
> Just in case you are wondering, acting on an invalid subpoena is $1,000
> min fine. Further, if you are acting in bad faith, the court can create,
> at carrier expense, a court-supervised monitor of your compliance to
> ensure due diligence. Any violations detected by the monitor can result
> in additional fines.
>
> -Matt

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