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Ottawa, 24 July 2012
Ref. No.: 8663-C12-201015470
Ms. Elizabeth Manzoni
Convergia Networks Inc.
237 Hymus Blvd.
Pointe Claire, Québec
Dear Ms. Manzoni:
RE: Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration as a reseller
Commission staff notes that on 28 June 2012, Convergia Networks Inc. (Convergia) submitted its proposed customer notification texts with respect to its local VoIP 9-1-1 emergency service. Commission staff acknowledges and appreciates Convergia’s efforts to comply with the 9-1-1 obligations of local VoIP service providers.
Commission staff has reviewed the information provided and considers that, in order to comply with the directives in Telecom Decision 2005-211 and Telecom Decision
2005-61,2 Convergia is requested to provide to the Commission the following:
a) a copy of the proposed telephone set warning sticker, or the text that would appear on the sticker, which indicates (i) that when making 9-1-1 calls customers must be prepared to provide their present address/location, and (ii) where to find additional information regarding VoIP 9-1-1 service.
Accordingly, Convergia is requested to file the additional information requested above for Commission review, by 7 August 2012.
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 and registration as a reseller”. The letter should be submitted using the online service on the Commission’s website (www.crtc.gc.ca). Click on the “Telecommunications Sector”, then “Submit a telecom-related document online” and select the “other” option. Address your submission to
Canadian Radio-television and Telecommunications Commission
A copy of this letter and all subsequent correspondence will be placed on the public record of the above noted file. If appropriate, the company may designate certain information contained in its response as confidential.3
‘Original signed by M. Murray’
Director, Regulatory Implementation
c.c.: M. Holmes, CRTC, (819) 953-5123, email@example.com
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 above.
[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 (as appropriate to each company).
 In Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005 (Telecom Decision 2005-21), the Commission mandated all local VoIP service providers to provide 9-1-1 service.
 In Follow-up to Emergency service 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, the Commission mandated local VoIP service providers to submit to it 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.
 The company may file certain information in confidence if the information falls into a category listed in subsection 39(1) of the Telecommunications Act. Essentially, the company can file two versions of its reply: one containing the confidential information and the word “Confidential” clearly marked on the letter; and another for the public record, in which the confidential information is omitted and replaced by a “#” sign. In general, confidential information is not released on the public record to protect proprietary information, and only the non-confidential version is posted on the Commission’s website. For more information on the process for filing information in confidence with the Commission, see Broadcasting and Telecom Information Bulletin CRTC 2010-961, available on the Commission’s website at http://www.crtc.gc.ca/eng/archive/2010/2010-961.htm.
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