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Ottawa, 4 March 2011
Our Reference: 8663-C12-201015470
Mr. Shaji Palackeal
Global Communication Network Inc.
2 Orleans Drive
Dear Mr. Palackeal:
Re:Obligations of local VoIP service providers with respect to 9-1-1 emergency service
On 7 February 2011, Global Communication Network Inc. (GCN) submitted its proposed customer notification texts with respect to its local VoIP 9-1-1 emergency service. Commission staff has reviewed the submission and considers that, in order for staff to evaluate compliance with the directives of Telecom Decision 2005-21 and Telecom Decision 2005-61, GCN is to respond to the following requirements not present in the above-noted submission:
a) confirm to the Commission explicitly that, as a VoIP provider, GCN is currently providing 9-1-1 service;
b) identify and provide the VoIP 9-1-1 notification texts the company proposes to use under each of the following categories, utilizing the attachment to this letter as your guideline to cover in detail the points therein, using a similar order and associated headings and ensuring the text is user-friendly and succinct:
- starter kit notifications (both inside and outside the kit);
- marketing / point of sale notifications; and
- terms of service notifications.
c) replace, on the front page of GCN’s website, “E911 services” with “9-1-1 Services”. The reason for this replacement is that Enhanced 9-1-1 or E 9-1-1 is currently unavailable with nomadic VoIP services;
d) provide a copy of the telephone set warning sticker, or the text that would appear on the sticker, which indicates to the customer that, when dialing 9-1-1 the customer must be prepared to provide their present address/location, and in addition to also note on the sticker that for more details, visit GCN’s website (insert the company’s website name);
e) confirm that the business street address for GCN is as shown on this letter, otherwise provide the correct address;
f) provide an online link to its VoIP 9-1-1 terms of service, with the document labelled as such, on each page of its website associated with local VoIP service; and
g) confirm to the Commission in response to this letter that GCN has requested to be registered with the Commission as a reseller, or if already registered to confirm the company name under which it has registered and the date of registration.
Accordingly, GCN is to submit the above-noted information for Commission review, no later than 15 calendar days from the date of this letter.
The company’s letter is to indicate the reference number noted above with the subject title “Obligations of local VoIP service providers with respect to 9-1-1 emergency service”. The letter can be submitted using the online service at the Commission’s website (www.crtc.gc.ca) under the Telecommunications Sector link, by selecting the option «Submit a telecom-related document online» and further selecting the application type «other». Address your submission to:
Robert A. Morin
Canadian Radio-television and Telecommunications Commission
Should you have any questions regarding the information requested in this letter, please do not hesitate to contact us.
‘Original signed by N. Webster Cole’ (for)
Senior Manager, Tariffs
cc: C. Abbott, CRTC (819) 997-4509
SUGGESTED STARTER KIT NOTIFICATIONS
External Starter Kit Notification:
On the outside of the starter kit, (company name) will place the following customer notification in English/French (as appropriate):
VoIP 9-1-1 emergency service is different than traditional telephone 9-1-1 services. See enclosed documents for further important details.
Inside Starter Kit:
Inside the starter kit, (company name) will include documentation/user tips with the following text in English/French (as appropriate):
IMPORTANT 9-1-1 INFORMATION
We want to make sure that you are aware of important differences in the way 9-1-1 service operates with a VoIP phone when compared with traditional telephone service. Here’s what you need to keep in mind:
Differences between traditional 9-1-1 service and VoIP phone 9-1-1.
With traditional phone services, your 9-1-1 call is sent directly to the nearest emergency response centre. With VoIP phone service, your 9-1-1 call is forwarded to a third-party service provider that will automatically or manually route your call to the emergency response centre.
Remember to verify your location.
Because you can move your VoIP phone between locations and because, for technical reasons, the emergency operator may not have your name, location or contact information available, you must immediately inform the emergency operator of your location and contact particulars any time you call 9-1-1. Do not risk sending police or ambulance services to the wrong location.
Be prepared during any service interruption.
VoIP phone service depends not only on your continued subscription (and payment) for the service, but also on Internet connectivity and power to function. In the event of power, network, or Internet outages (including congestion), or if your service is disconnected or suspended due to non-payment, you may experience a failure, disruption or delay in your 9-1-1 service. We recommend that you keep an alternative phone service (such as a cellular telephone) handy to increase the reliability of your access to emergency services during any service interruption.
Do not disconnect.
Until you are told to do so by an emergency dispatcher, do not disconnect your 9-1-1 call. If you are inadvertently disconnected, call back immediately.
Keep your service address up to date.
(Company name) will attempt to provide the emergency operator with your service address, so please ensure that your information on file with us is always accurate and updated. If you do not do this (for example, if you are unable to speak during a 9-1-1 call), the emergency operator may assume that you are calling from the last registered address.
Inform other users.
You must notify members of your household and other potential users of your VoIP phone service of the nature and limitations of 9-1-1 emergency calls. To make this easier, attach the included stickers in a visible location on your telephone sets.
Limitations of Liability.
(Company name)’s terms of service limit and disclaim liability related to VoIP 9-1-1 service, so please read these carefully.
For a complete description of our VoIP 9-1-1 service, please see (company name)’s terms of service at www.company.name.website.ca
Telephone Set Stickers Inside Starter Kit:
Inside the starter kit, (company name) will include telephone set warning stickers with the following text:
When dialling 9-1-1, be prepared to provide your address/location.
For more details visit www.company.name.website.ca
The URL indicated on the warning sticker goes to (company name)’s website, on which each page will contain a link to (company name)’s Terms of Service and other important notification items.
SUGGESTED MARKETING / POINT OF SALE NOTIFICATIONS
Printed Marketing Materials:
For its printed marketing materials, (company name) intends to use the following customer notification texts (examples) depending on the nature of the advertisement or promotion:
VoIP phone emergency 9-1-1 features differ from traditional 9-1-1 services. See sales representative for further details.
VoIP phone emergency 9-1-1 features differ from traditional 9-1-1 services. Visit www.company.name.website.ca for more information.
Note: Notifications similar to those above are also required in the event a local VoIP service provider is making use of other forms of advertising and or promotion such as with television, radio, or other forms of media.
When customers call (company name) to request activation of their VoIP service, (company name)’s representative will notify them of the documents in the starter kit and how the VoIP emergency 9-1-1 services differ from traditional 9-1-1 services. Once their VoIP service is ready to be activated, customers will, through the Internet, log onto their account management site to activate their 9-1-1 service. As part of the activation process, text similar to the printed 9-1-1 documents will be presented to the customers and the customers will be presented with the following in English/French (as appropriate) and their selections will be captured:
I agree that I have read and understand the 9-1-1 service limitations described
[link: "I Agree" (to proceed with activation)]
[link: "I Do Not Agree" (to cancel activation)]
Customer Service/Point of Sales:
(Company name)’s customer service and sales representatives will be fully versed in the contents of the VoIP 9-1-1 documents for discussion with potential customers.
On-line marketing on (company name)’s website will contain a link to its Terms of Service prefaced with the following text:
VoIP phone emergency 9-1-1 features differ from traditional 9-1-1 emergency services. Visit [link] [www.company.name.website.ca] for more information
SUGGESTED TERMS OF SERVICE NOTIFICATIONS
THIS SECTION CONTAINS IMPORTANT PROVISIONS, INCLUDING THOSE REGARDING 9-1-1 SERVICE
Description: VoIP services allow you to make or receive telephone calls over the Internet to or from the public switched telephone network. The nature of VoIP telephone calls, while appearing similar to traditional telephone calling services, create unique limitations and circumstances, and you acknowledge and agree that differences exist between traditional telephone service and VoIP telephone services, including the lack of traditional 9-1-1 emergency services.
9-1-1 service: Because of the unique nature of VoIP telephone calls, emergency calls to 9-1-1 through your VoIP service will be handled differently than traditional phone service. The following provisions describe the differences and limitations of 9-1-1 emergency calls, and you hereby acknowledge and understand the differences between traditional 9-1-1 service and VoIP calls with respect to 9-1-1 calls placed to emergency services from your account as described below.
Placing 9-1-1 calls: When you make a 9-1-1 emergency call, the VoIP service will attempt to automatically route your 9-1-1 call through a third-party service provider to the Public Safety Answering Point (“PSAP”) corresponding to your address of record on your account. However, due to the limitations of the VoIP telephone services, your 9-1-1 call may be routed to a different location than that which would be used for traditional 9-1-1 dialling. For example, your call may be forwarded to a third-party specialized call centre that handles emergency calls. This call centre is different from the PSAP that would answer a traditional 9-1-1 call which has automatically generated your address information, and consequently, you may be required to provide your name, address, and telephone number to the call centre.
How your information is provided: The VoIP service will attempt to automatically provide the PSAP dispatcher or emergency service operator with the name, address and telephone number associated with your account. However, for technical reasons, the dispatcher receiving the call may not be able to capture or retain your name, phone number or physical location. Therefore, when making a 9-1-1 emergency call, you must immediately inform the dispatcher of your location (or the location of the emergency, if different). If you are unable to speak, the dispatcher may not be able to locate you if your location information is not up to date.
Correctness of information: You are responsible for providing, maintaining, and updating correct contact information (including name, residential address and telephone number) with your account. If you do not correctly identify the actual location where you are located, or if your account information has recently changed or has otherwise not been updated, 9-1-1 calls may be misdirected to an incorrect emergency response site.
Disconnections: You must not disconnect the 9-1-1 emergency call until told to do so by the dispatcher, as the dispatcher may not have your number or contact information. If you are inadvertently disconnected, you must call back immediately.
Connection time: For technical reasons, including network congestion, it is possible that a 9-1-1 emergency call will produce a busy signal or will take longer to connect when compared with traditional 9-1-1 calls.
9-1-1 calls may not function: For technical reasons, the functionality of 9-1-1 VoIP emergency calls may cease or be curtailed in various circumstances, including but not limited to:
Failure of service or your service access device—if your system access equipment fails or is not configured correctly, or if your VoIP service is not functioning correctly for any reason, including power outages, VoIP service outage, suspension or disconnection of your service due to billing issues, network or Internet congestion, or network or Internet outage in the event of a power, network or Internet outage; you may need to reset or reconfigure the system access equipment before being able to use the VoIP service, including for 9-1-1 emergency calls; and changing locations—if you move your system access equipment to a location other than that described in your account information or otherwise on record with (company name).
Alternate services: If you are not comfortable with the limitations of 9-1-1 emergency calls, (company name) recommends that you terminate the VoIP services or consider an alternate means for accessing traditional 9-1-1 emergency services.
Inform other users: You are responsible for notifying, and you agree to notify, any user or potential users of your VoIP services of the nature and limitations of 9-1-1 emergency calls on the VoIP services as described herein.
Liability: Customers are advised to review this section with respect to (company name)’s limitations of liability (provide here a full description of the company’s limitations of liability with respect to VoIP 9-1-1 emergency service, as appropriate to each company).
 In Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005 (Decision 2005-21), the Commission mandated that all local VoIP service providers are required to provide 9-1-1 service.
 In Follow-up to Emergency services obligations for local VoIP service providers, Decision 2005-21 – Customer notification requirements, Telecom Decision CRTC 2005-61, 20 October 2005 (Telecom Decision 2005-61), paragraphs 9 and 15, local VoIP service providers are required to submit to the Commission their proposed customer notification texts, prior to use, for Commission review. The proposed texts must adhere to Emergency Services Working Group Consensus Report ESRE039D – Customer Notification Issues re: 9-1-1 Calls on VoIP, 21 July 2005 (the Report), and paragraphs 11 to 13 of Telecom Decision 2005-61.
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