policies.[1] ComNet maintains a company-specific policy, but that policy was drafted based on CITIC's guidance.[2]
ComNet leverages CITIC's network operations center ("NOC"), located in Hong Kong, for "first tier monitoring" against cyber incidents or disruptions.[3] "All system alarms and network management data are sent to the NOC . . . ."[4] Further, CITIC's NOC maintains records of all alarms and access logs generated by ComNet's systems.[5]
ComNet representatives informed the Subcommittee that its data center and all backed-up information are located in the United States and that it controls access to all U.S. records and data systems.[6] However, records of Team Telecom's site visits indicate that ComNet used CITIC's data center in Hong Kong as a backup and that ComNet's wholesale billing records "are maintained in Hong Kong."[7] Team Telecom's records from the 2018 site visit also note that ComNet's VoIP customer and billing records are accessible to Hong Kong personnel.[8] ComNet informed the Subcommittee, by contrast, that its parent companies do not have direct access to these records and that they would need to request access from ComNet and follow ComNet's local procedures.[9]
ComNet provides various communications services in the United States with its Section 214 authorizations. ComNet provides international telecommunication services, consisting of wholesale direct dial services, wholesale SMS services, retail prepaid calling card services, and VoIP services.[10] Pacific Networks primarily provides international resold data services.[11] Together, the companies serve a mix of carrier customers, individual end-customers, and enterprise customers in the United States.[12]
- ↑ Id.
- ↑ Id.
- ↑ Id.
- ↑ DHS00460PSI-65, at DHS00462PSI.
- ↑ Id.
- ↑ Briefing with ComNet (Apr. 13, 2020).
- ↑ DHS00460PSI-65, at DHS00463PSI; DHS00466-71, at DHS00468PSI.
- ↑ DHS00466-71, at DHS00470PSI.
- ↑ See Letter from Lerman Senter PLLC, counsel to ComNet, to the Subcommittee (June 2, 2020) (on file with the Subcommittee).
- ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); DHS00462PSI, DHS00467PSI.
- ↑ DHS00462PSI.
- ↑ ComNet Presentation to the Subcommittee (Apr. 13, 2020) (on file with the Subcommittee); Briefing with ComNet (Apr. 13, 2020).
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