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Ottawa, 8 August 2012


To: Ruth Milkman
Chief, Wireless Telecommunications Bureau
Federal Communications Commission

Re:  Privacy concerns due to the unmasking of blocked Caller ID information

Dear Ms. Milkman:

I am writing this letter to share with you our concerns about services available to Canadian wireless subscribers that violate the privacy expectations of the calling party.

It has been brought to CRTC staff’s attention that certain third-party applications or services available to Canadian wireless phone subscribers can circumvent the calling party’s attempt to protect his or her privacy without the party’s knowledge. For example, TrapCall service, which is provided by Teltech Systems, enables users to unmask a telephone number that has been blocked using the Caller ID blocking feature.

As you are aware, the protection of subscribers’ privacy is a fundamental telecommunications policy objective. In Canada, this objective is reflected in section 7(i) of our Telecommunications Act. Over the years, the CRTC has implemented a number of regulatory measures designed to safeguard the confidentiality of customer information and protect the privacy of consumers (e.g. the requirement for certain telecommunications service providers to offer features such as Caller ID blocking and Call Trace).

CRTC staff considers that applications or services such as TrapCall violate the privacy expectations of subscribers who use the Caller ID blocking feature. In order to address this issue, we have directed questions to Canadian wireless carriers to better understand the pervasiveness of the problem and to explore possible technical and regulatory solutions. However, any action that the CRTC may take would only be applicable to telecommunications service providers operating in Canada.

In regards to services such as TrapCall, it is our understanding that the FCC had determined that the Truth in Caller ID Act does not cover the blocked Caller ID information unmasking issue and that the record was insufficient to initiate a proceeding on this issue1. Further to a conversation with Lisa Horne from the FCC earlier this year, the CRTC would appreciate obtaining more information about how the FCC is dealing with this issue.

  1. Do you have any information on how widespread these services are?
  2. Does the FCC have plans to investigate solutions to address the unmasking of blocked Caller ID information?
  3. Considering how TelTech Systems’ TrapCall service works, would FCC staff consider that this service is breaking the 800 service/toll-free calls rules, given the following passage on the FCC’s website: “FCC rules, however, prevent parties that own toll-free numbers from reusing or selling the telephone numbers identified through ANI without the subscriber’s consent”?
  4. Are you aware of any carriers in the U.S. who have taken actions to address this issue?

Any information or assistance you can provide is appreciated.

Yours sincerely,

Original signed by Lynne Fancy for

Chris Seidl
Executive Director

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