ARCHIVED - Letter

Ottawa, 19 June 2014

Reference: 8665-P8-201400762

Via email

Mr. Philippe Gauvin
Senior Counsel - Regulatory Law & Policy
Bell Canada
160 Elgin Street, Floor 19
Ottawa, Ontario  K2P 2C4
bell.regulatory@bell.ca

Ms. Suzanne Morin
General Counsel – Regulatory & Privacy Chief
Bell Aliant Regional Communications L.P.
160 Elgin Street, Floor 19
Ottawa, Ontario  K2P 2C4
regulatory@bell.aliant.ca

Dear Sir/Madam:

Subject:  Public Interest Advocacy Centre (PIAC) and the Consumers’ Association of Canada (CAC)’s applications regarding Bell’s use of customer information
(CRTC file #8665-P8-201400762) – Requests for Information

On 27 January 2014, the Commission received an application from the Public Interest Advocacy Centre  and the Consumers’ Association of Canada, collectively PIAC/CAC, in respect of data collection and use practices by BCE Inc., Bell Canada, Bell Mobility Inc., and Bell Aliant Regional Communications, Limited Partnership; and their affiliates (collectively, the Bell Companies).  PIAC/CAC raised concerns related to the Bell Companies’ Bell Relevant Ads Program (the Program).  PIAC/CAC requested that the Commission find that the Program:

• is contrary to the Telecommunications Act, 
• violates the Commission’s confidential customer information rules,
• is contrary to Commission’s ITMP framework and the privacy principle established in the ITMP framework, and
• violates Section 36 of the Telecommunications Act.

PIAC further requested that the Commission exercise its authority under Sections 24 and 32(g) of the Telecommunications Act, to stop the collection and use of information about Canadians by the Bell Companies for the purposes of behavioural advertising.
Section 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information or documents where needed.
Commission staff requests that the Bell Companies respond to the attached requests for information associated with the above-noted Part 1 application.
Responses to these interrogatories are to be filed with the Commission by 10 July 2014.

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

Yours sincerely,

Nanao Kachi
Director, Social and Consumer Policy
Consumer Affairs and Strategic Planning

c.c.:     Geoffrey White, PIAC (gwhite@piac.ca)
John Lawford, PIAC (jlawford@piac.ca)      
Bruce Cran, CAC (bcranbiz@telus.net)
Antica Corner, CRTC antica.corner@crtc.gc.ca

Requests for Information

1. Please provide a list of all the characteristics (including, but not limited to, demographic characteristics and interest categories) that can be used by a customer of the Relevant Ads Program to create an advertising profile. What information sources does the Bell Companies use to derive a specific subscriber’s characteristics in order to determine if that subscriber matches an advertising profile?  Please provide the sources for each characteristic.
2. Are the interest categories for a mobile subscriber who has not opted-out of Relevant Ads Program determined based only on the IP addresses and URLs of the websites visited by that subscriber?  If not, what are the other sources of this information and how is it collected?
3. Are the categories of interest and other characteristics populated in the Relevant Ads Program server for mobile subscribers who have opted-out of the Program?
4. Please confirm that the messaging between the Bell Relevant Ads Server and the websites of the customers of the Program that is specific to a subscriber is limited to the following:
1. a request to confirm that a subscriber is in the Program and has an advertising profile and
2. the encrypted profile ID(s) for the advertising profiles that the subscriber meets is returned, if the subscriber is in the Program.

If not, what other messages specific to a subscriber are passed between the Bell Relevant Ads Server and the customers’ websites?

5. Please provide samples of the types of reports provided to customers of the Relevant Ads Program.
6. The Bell Companies’ notice regarding how its subscribers’ information will be used indicates it will share information with other companies and will allow these companies to produce limited business and marketing reports. 
1. Do these companies have direct access to information related to Bell’s subscribers?
2. What information can these companies access and what are the sources of this information? 
3. Is it limited to information about Bell Mobility subscribers as per the example in the notice?
4. If a subscriber has opted-out of the Relevant Ads Program, is their information excluded from the reports?

Date modified:

2014-06-19