Letter
Ottawa, 1 November 2006
File No: TEL 8698-C12-14/01
Ms. Cindy Grauer
Suite 602
134 Abbott Street
Vancouver , BC V6B 2K4
cg@gstrategies.com
Dear Ms. Grauer:
Re: Decision CRTC 2001-475 - N11 211
In your letter of 4 October 2006 to Ms. Fiona Gilfillan, Acting Executive Director, you posed several questions to Commission staff seeking clarification of several issues concerning the implementation and use of N11 211.
The abbreviated dialing code 211 was assigned by the Commission in Allocation of three-digit dialing for public information and referral services , Decision CRTC 2001-475, 9 August 2001 . The following responses to your questions are taken from this Decision.
Question 1: What are the terms and conditions of use of 211 and what approvals are required?
The terms and conditions set by the Commission for the use of N11 211 follow the guidelines established by the Commission in Decision 2001-475 for the use of N11 codes in general (paragraph 44). The Commission also determined that telecommunications carriers are to bear the cost of implementing 211. The Decision also noted that there would be no cost for callers to use 211 services.
The Commission did not make any specific rulings on what approvals would be required to provide 211 services. However, in accepting the United Way et al. 's proposal, the Commission specifically noted that:
• 211 would be assigned to an I & R service and not to the United Way organization per se , although the United Way , in collaboration with other organizations and with approval from the appropriate level of government , would spearhead the effort to establish a 211 centre [ . ] [emphasis added]
From this it can be taken that the Commission recognized that the United Way would be involved in the development of 211 services, but subject to any government approval that might be required.
Question 2: In addition to adherence to federal and provincial laws respecting privacy and protection of personal information, what if any, are the restrictions around the use of data generated by a 211 service?
Staff notes that this matter was not dealt with by the Commission in Decision 2001-475, and staff can provide no further guidance in this matter other than to say the use of data would be governed by other provincial and federal laws, such as the Personal Information Protection and Electronic Documents Act . Information on the PIPED Act can be found at http://www.privcom.gc.ca/fs-fi/02_05_d_16_e.asp.
Question 3: What organization, if any holds the rights to 211?
In Canada all the N11 numbers are assigned to services. These abbreviated dialing codes are not "owned" by particular companies or entities. In Decision 2001-475 the Commission, in paragraph 44, set out the guidelines to be used for allocating unused N11 codes. The second criterion is that N11 codes should be assigned to a service or services rather than a specific organization.
In arriving at this conclusion, the Commission in its reasoning, at paragraph 37, considered that N11 should be allocated to services rather than to any specific organizations as assigning an N11 code to an organization could be perceived as conferring an undue preference on one organization over another. The Commission went on to say that any organization providing N11 services should present some evidence of stable organizational capabilities and plans so as to be able to sustain delivery of these services.
Further, the Commission, in accepting the United Way et al. proposal for the use of N11 211 for information and referral services, noted that the United Way 's proposed model met the criteria for 211 access. This is clear from the notation above in the response to Question 1. Thus, no organization or entity holds the rights to 211. It is and remains a public numbering resource.
Question 4: Other than AIRS accreditation is any other certification required?
The Commission did not make any determinations on any certifications that would be required to provide 211 services. Staff considers that any certifications that would be required would be determined by the appropriate level of government when it approved the provision of 211 services as noted above.
Sincerely,
Paul Godin
Acting Director General
Competition, Costing and Tariffs
cc: Fiona Gilfillan
Bill Mason
Date Modified: 2006-11-01
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