1) Subsentio provides end-to-end management of the lawful intercept process for companies to comply with CALEA and be protected under "Safe Harbor." 2) When a company receives a court order for surveillance, they notify Subsentio who reviews the order, initiates the intercept, and manages it until it expires. 3) Subsentio's solutions help companies comply with surveillance laws in a cost-effective manner while protecting customer privacy.

1. SURVEILLANCE MANAGEMENT
CALEA Compliance puts You in Safe Harbor &
Protects Customer Privacy
2001 East Easter Avenue, Suite 302, Centennial, Colorado 80122 • 303-794-6936 • info@subsentio.com • www.Subsentio.com
© 2013 Subsentio, Inc.
The Steps to Compliance
Under “Safe Harbor,” Subsentio provides end-to-end management of the lawful intercept process.
Subsentio solutions are expertly installed and integrated into your network, rigorously tested and
continuously monitored.
1. You receive a court order: A Law Enforcement Agency (LEA) serves your company with a
Court order for a Legally Authorized Electronic Surveillance (LAES)
2. You Notify Subsentio: Complete the Service Provider Authorization form found on our
website and email it, along with the Court order, to courtorder@subsentio.com.
3. Subsentio Review: We review the Court order to validate its correctness. Should the court
order need correction (about 15% of them do), Subsentio will interact with law enforcement
to effect the necessary changes. Remember, the purpose of the Court order is to obtain
evidence for use in court.
4. Subsentio Surveillance: We initiate the electronic intercept and begin comprehensive
administration, tracking and reporting.
5. Successful Compliance: The Legally Authorized Electronic Surveillance is discontinued
when the legal authority expires. Subsentio notifies law enforcement agency.
“Safe Harbor” indemnifies you from non-compliance penalties, while protecting your customers’ privacy.
The Cost of Self Compliance
Doing it Yourself
So, you want to do it yourself? Here are some functions and costs that you
need to consider. The equipment supplier provides the technical solution.
You pay for it. You install it. You maintain it. That’s just the start. Your
network also has to be able to establish a connection to the requesting law
enforcement agency for transmission of the data.
Now let’s talk about personnel. When you receive a Court order, it needs to
be reviewed for authenticity and correctness by an attorney. The Court order
needs to be managed by personnel with security experience and preferably
with security clearances. Specific information needs to be maintained for each lawful intercept.
Then there needs to be personnel who are available 24x7 for both receipt and management of a
Court order. They then hand off the order to specified technicians who can initiate, test, intercept
and transmit the requested information to the requesting agency. Self-compliance requires technical,
legal, regulatory and law enforcement expertise that most carriers simply don’t have and can’t afford.
TheCALEAComplianceCompany
• CALEA is the
Communications Assistance
for Law Enforcement Act
• This law mandates your
compliance
• When you are compliant, you
are in “Safe Harbor”
• Subsentio provides end-to-
end management of the
lawful intercept process
• Partnering with Subsentio
indemnifies you against legal
problems and civil penalties
up to $100,000

2. THE CALEA Compliance Company
Surveillance Management
Subsentio is a CALEA Service Bureau
Technical Solutions
Court Order Validation
Law Enforcement
Monitoring Centers
Network Operations Center
Mediation
Platform
Warrant Administration
& Provisioning
Wideline
Network
Cable
Network
Mobile
Network
ISP
Network NYPD
FBI
U.S. Marshals
Your Name Goes Here
Has met the requirements for CALEA compliance and is deemed to be in SAFE HARBOR
2015
Safe Harbor
Compliance
Date
Signed
Safe Harbor Indemnification
We Insure You
The CALEA Act mandates compliance. You must comply or
face potential legal action. This is not a revenue producing
service. To go it alone and install both the necessary
technical and administrative support systems is costly, to
say nothing of the difficulty in recruiting personnel with the
expertise to support compliance.
Subsentio has a better — and far more cost effective way —
for you to be Safe Harbor compliant.
Subsentio indemnifies you for up to $100,000 from any civil
penalties that could be levied on you for not complying with
a Court order. Our entire system and processes are reviewed
on an annual basis for continuing compliance.
SUBSENTIO’S SYSTEM IS THE SOLUTION
The Subsentio System
Subsentio is a Trusted Third Party Service Bureau. We deliver customized CALEA compliance solutions
to communications service providers throughout the U.S. Subsentio provides a triage of three
integrated compliance services:
1. Technical solutions that enable you
to provide the mandated intercept
capability.
2. Upon receipt of a valid court order,
Subsentio’s security department
implements and manages the
surveillance process for you.
3. Subsentio’s staff provides continual
administrative support through
our Compliance Program, which
indemnifies you against possible
non-compliance penalties up to
$100,000.
This management of the intercept
process enables you to be in “Safe
Harbor.” Subsentio’s system is the solution.
What is CALEA?
Communications Assistance for Law Enforcement Act (CALEA)
The technical nature of the law makes it one of the telecommunications industry’s
least understood and, for carriers, hardest to implement mandates — but it is a
required mandate.
Congress passed CALEA in 1994 and ordered the Federal Communications
Commission to administer the law. CALEA states that “a telecommunications
carrier shall insure that its equipment facilities, or services that provide
a subscriber’s service with the ability to originate, terminate or direct
communications, be capable of enabling the government, pursuant to a Court
order or other lawful authorization, to intercept, to the exclusion of any other communications, all wire
and electronic communications carried by the carrier.”
That’s the law! When you are in compliance with CALEA, you are considered to be in “Safe Harbor.”
ABOUT CALEA
Subsentio vs. Competition
Feature Benefit Subsentio Competition
Indemnification
Subsentio is the only company that indemnifies its clients from any civil
penalties that could be levied on a service provider for not complying
with a court order up to $100,000. 3 ?
CALEA Compliance
Program
Subsentio is the only company that provides a CALEA compliance
program. The program includes testing with FBI/DEA forensic
equipment, customer CALEA training, FCC filing information, annual
performance testing, Subsentio’s Guide to CALEA Compliance with
federal and state statutory guidelines and more.
3 ?
FBI Security Clearances
Subsentio’s staff includes former FBI officials who have retained their
security clearances that allow them to review classified documents
on behalf of their clients and interact with state and Federal law
enforcement agencies.
3 ?
Court Order Legal
Review
Subsentio’s legal staff reviews all court orders to confirm they are
facially valid. Many are not in which case Subsentio works with Law
Enforcement to correct the errors before a court order is initiated.
This protects Subsentio and the client from being sued for any right to
privacy issues and it helps law enforcement with collecting intelligence
that will be admissible in court.
3 ?
Law Enforcement Staff
Many of Subsentio’s staff worked at the FBI and DEA. They even
helped to write the CALEA laws. The relationships that these personnel
have within the Law Enforcement community acts as a buffer between
our clients and law enforcement when and if problems arise.
3 ?
US Based Lawful
Intercept Standards
All of Subsentio’s solutions are based on US Standards not European
Standards. This is an important distinction because European
standards cannot separate call data from call content. Since most
US court orders are for call data only, a solution that uses European
standards would be a violation of US law because call content would
be delivered without authorization from the court.
3 ?
ATIS Membership
Subsentio is the only Trusted Third Party with representation on the ATIS
CALEA standards body. The Chairperson for the VoIP and Broadband
CALEA standards body is a former Subsentio CTO. 3 ?