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Ottawa, 13 October 2011
File No.: 8740-T66-201109918
BY E-MAIL
Mr. Hal Reirson
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS Communications Company
21-10020-100 Street NW
Edmonton, Alberta
T5J 0N5
hal.reirson@telus.com
RE: Tariff Notice 412 and 412A – Terms of Service
Dear Sir:
The Commission received an application by TELUS Communications Company (TCC) under Tariff Notice 412, dated 23 June 2010, in which the company proposed a revision to its General Tariff item 112 – General Terms of Service, The Company’s Rights.
In a letter dated 7 July 2011, Commission staff informed TCC that it was continuing its analysis of this application and that, consequently, the application and all associated subsequent revisions would not be approved on an interim basis on the 15th calendar day following their receipt.
Subsequently, Commission staff issued a request for information to TCC, dated 18 July 2011. In a letter dated 25 July 2011, TCC filed its response to the request for information along with Tariff Notice 412A, which amended the company’s initial application.
Based on Commission staff’s analysis of the information received to date, TCC is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 27 October 2011. Consequently, the Commission is unable to dispose of the application within 45 business days of its receipt. The Commission intends to dispose of this application by the end of December 2011.
Yours sincerely,
‘Original signed by S. Bédard’
Suzanne Bédard
Senior Manager, Tariffs
Telecommunications
cc: Martin Brazeau, CRTC (819) 997-3498, martin.brazeau@crtc.gc.ca
ATTACHMENT
Refer to the proposed amendment to item 119.5(e).
1. Proposed item 119.5(e) includes the phrase “provided the information is requested for and to be used for that purpose.”
Explain the purpose for which the information would be required and used.
2. Would the “sharing” of customer payment information involve the exchange of this information between the agent of TCC and other telecommunications service providers (TSPs) or only the disclosure of customer payment information held by TCC to other TSPs, through an agent for TCC?
3. Explain why, in TCC’s view, it is necessary to exempt this disclosure/exchange of customer payment information from the requirement to obtain the customer’s express consent.
4. In contrast to the other provisions of item 119.5(e), which provide for the disclosure of customer confidential information as between TCC and its agents, the proposed tariff amendment provides for agents of TCC to share TCC’s customer payment information with other TSPs.
Describe what oversight and accountability measures TCC will have in place to ensure that its agents are appropriately safeguarding customers’ payment information.
5. Explain why an agent should be allowed to disclose customer payment information to another TSP when TCC is not permitted to do so without the specific protections provided in item 119.5(c) (i.e. only in cases where the information is required for the efficient and cost-effective provision of telephone services, and disclosure is made on a confidential basis with the information to be used only for that purpose).
6. Describe how customers would be informed (i) of this provision; and (ii) of particular instances of its applications.
7. In Forbearance from the regulation of retail local exchange services, Telecom Decision CRTC 2006-15, 6 April 2006, as varied by Order in Council P.C. 2007-532, the Commission forbore from the regulation of retail local exchange services provided by incumbent local exchange carriers (ILECs) under certain criteria. However, in that decision, the Commission considered that it was necessary to maintain consumer confidentiality provisions. The Commission noted that the obligation to comply with the Commission's rules regarding the confidentiality of customer information would apply to all ILECs in forborne markets.
In its 25 July 2011 submission in response to Commission staff’s request for information, TCC indicated that the proposed condition would enable the company to align its business practice for customers of regulated services to be consistent with industry practice for unregulated services.
Describe how TCC’s business practice for customers of unregulated services differs from TCC’s business practice for customers of regulated services with respect to the sharing of customers’ payment information.
8. Explain the choice of the term “telecommunications service providers” as opposed to “telephone company” in the proposed wording.
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