ARCHIVED -  Telecom Order CRTC 97-1451

Telecom Order

Ottawa, 9 October 1997

Telecom Order CRTC 97-1451

In response to the Commission's letters of 17 July and 1 August 1997, AT&T Canada Long Distance Services Company, Call-Net Enterprises Inc., the Canadian Cable Television Association (CCTA), Clearnet Communications Inc. (Clearnet), Consumers' Association of Canada, Fédération nationale des associations de consommateurs du Québec and the National Anti-Poverty Organization (CAC/FNACQ/NAPO), fONOROLA Inc., the Government of British Columbia, MetroNet Communications Corp., Stentor Resource Centre Inc. (Stentor) on behalf of BC TEL, Bell Canada, The Island Telephone Company Limited, Maritime Tel & Tel Limited, MTS NetCom Inc., The New Brunswick Telephone Company, Limited, NewTel Communications Inc., and TELUS Communications Inc., and TelcoPlus Services Inc., filed their comments on, among other matters, whether there is a need for a separate call to confirm an end-customer local service transfer order, whether confirmation by voice recording should be acceptable and whether an exclusive toll-free number to confirm the transfer should be available.

File Nos.: 8638-C12-01/97 & 96-2376

1. Most parties submit that a separate call for the purpose of confirming a transfer order is neither necessary nor warranted. Instead, they submit that Local Exchange Carriers (LECs) should be allowed to transfer the end-customer to an independent third-party or to an Interactive Voice Response (IVR) system at the end of the original call to confirm the transfer order. Parties opposed to a separate second call, argue that it would be costly, would delay end-customer service transfer, would increase customer confusion and frustration, and would impede the creation of the local service market. They also maintain that safeguards already exist or could be implemented to protect customers against unsolicited local service transfers or high pressure tactics.

2. Most parties also favour the use of a multi-purpose toll-free telephone number whose menu gives access to an IVR system in order to confirm a transfer order rather than a toll-free number solely dedicated to confirmation purposes. In the CCTA's view, this approach would provide a single point of contact for customers, would make the order process simpler, more efficient and effective and would reduce LECs' costs.

3. CAC/FNACQ/NAPO state that a separate second call to confirm a transfer order should be required in order to protect end-customers from unexpected solicitations and aggressive telemarketing tactics. A separate second call would offer end-customers time for a sober second thought before committing to a new LEC. CAC/FNACQ/NAPO further submit that this requirement would be neither unreasonable nor onerous and would provide added protection to LECs themselves.

4. A majority of parties support the use of voice recordings to confirm transfer orders. Some of them also propose that a standard set of questions or a standard script be used to confirm that end-customers consent to both, or either of, the transfer and the recording itself. CCTA finds that voice recording would reinforce the authorization process, would make it simpler, more efficient and effective, and would reduce costs.

5. CAC/FNACQ/NAPO and Stentor submit that voice recordings would nullify an important second process during which customers can soberly reflect on their decision without influence or pressure before confirming the order. Stentor is also concerned that voice recordings may be intrusive and offensive to end-customers. If the Commission permits the use of a voice recording to confirm an order, CAC/FNACQ/NAPO consider it essential that the recording include a script which clearly indicates that the customer is confirming a decision which was previously made in conversation with another LEC's representative.

6. The Commission considers that end- customers should have an opportunity for second thought before confirming the transfer of their local services to another LEC; however, the Commission is not convinced that a separate second call is necessary to achieve this goal. The Commission finds that transferring the end-customer to an independent third-party or to an electronic IVR system for the purpose of confirmation will afford end-customers sufficient opportunity to reflect on whether or not they want to transfer their local services to another LEC. Furthermore, the Commission considers that the procedures developed by the CRTC Interconnection Steering Committee's Customer Transfer Sub-Working Group and the significant incremental costs of acquiring a local customer will protect end-customers against unsolicited local service transfers. Consequently, the Commission does not consider it necessary to give end-customers a grace period during which they can either accelerate or cancel the transfer, as proposed by Clearnet.

7. The Commission also finds that using a multi-purpose toll-free telephone number with access to an IVR system or to an independent third-party in order to confirm a transfer order will sufficiently protect end-customers. Requiring LECs to provide a toll-free number dedicated to confirmation purposes is therefore not necessary.

8. Finally, the Commission is of the view that a voice recording, especially if it is of the original confirmation with the LEC's representative, will not afford end-customers a sufficient opportunity to reflect on their decision to switch LECs, since it would not provide end-customers the opportunity for a second interaction, as does an IVR system or the transfer of the original call to an independent third party.

9. In light of the foregoing, the Commission orders that:

a) a LEC must confirm each order to transfer local service to that LEC. Such confirmation may be obtained by transferring the end-customer, following the original order, to an independent third-party or to an IVR system for the purpose of confirming the local service transfer order;

b) a separate call to confirm an end-customer local service transfer order is not required;

c) LECs are not permitted to use voice recordings to confirm an end-customer local service transfer order;

d) LECs are not required to provide end-customers with a toll-free telephone number solely dedicated to order confirmation purposes; and

e) LECs who choose to provide end-customers with the opportunity to call back to confirm a transfer order may use a multi-purpose toll-free number with access to an IVR system, or to an independent third-party.

Laura M. Talbot-Allan
Secretary General

This document is available in alternative format upon request.