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ARCHIVED - Telecom Commission Letter addressed to Gary Jessop (RingCentral Canada Inc.)

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Ottawa, 2 December 2014

Our reference:  8663-C12-201015470

BY EMAIL

Mr. Gary Jessop
Partner
JESSOP & PROULX LLP
RingCentral Canada Inc.
5480 Canotek Road, Unit 21
Ottawa, Ontario,  K1J 9H7
gary.jessop@jplegalservices.com

Re: RingCentral Canada - Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration with the Commission ‒ File No.: 8663-C12-201015470

Dear Sir,

In light of the importance of 9-1-1 emergency service to the Canadian public, the Commission is working to ensure that local Voice over Internet Protocol (VoIP) service providers in Canada adhere to their obligations related to the provision of 9-1-1 service.Footnote 1 In this letter, certain information is being requested from RingCentral Canada Inc. (RingCentral).

There are three 9-1-1 and related obligations for local VoIP service providers: (1) to provide 9-1-1 service, (2) to inform customers of any limitations in the provision of 9-1-1 service, and (3) to register with the Commission as a reseller (or as a CLEC if they own or operate transmission facilities), and to obtain a basic international telecommunications services (BITS) licence.

With respect to the first obligation, RingCentral is requested to provide answers to the following questions, by 12 December 2014:

  1. Please confirm that RingCentral is providing 9-1-1 service in accordance with Telecom Decision 2005-21. If so,
    1. Indicate the 9-1-1 answering bureau that RingCentral uses, with which RingCentral has a direct contract.

      If RingCentral has no direct contract with the 9-1-1 answering and routing Indicate the 9-1-1 answering bureau that RingCentral uses, with which RingCentral has a direct contract.

      If RingCentral has no direct contract with the 9-1-1 answering and routing provider, indicate the intermediate company (ies) which RingCentral has a contract with. Provide proof of contract or executive attestation from the intermediate company that it provides RingCentral with 9-1-1 services by virtue of, or through, its direct contract with the 9-1-1 provider.

      Contact names, telephone numbers, and email addresses are to be provided for each company identified.

    2. Indicate the LEC or reseller from which RingCentral obtains its customers’ telephone numbers and other network services that enable it to offer local VoIP services.

      Contact names, telephone numbers, and email addresses are to be provided for each company identified.

    3. Confirm that RingCentral obtains, prior to commencement of service, the customer’s express consent, by which the customer acknowledges his/her understanding of the 9-1-1/E9-1-1 service limitations and indicate the method by which express consent is obtained.Footnote 2
    4. Confirm that RingCentral ensures that customers are able to update their most likely physical address online.
  2. If not, provide a detailed plan and a timetable for the provision of 9-1-1 service to Canadian customers.
  3. If RingCentral is an existing local VoIP service provider, indicate the number of customer lines served, broken down by access-dependent and access-independent (i.e. fixed vs. nomadic VoIP).
  4. Confirm whether RingCentral owns and operates its own transmission facilities in Canada.
  5. Provide RingCentral’s legal name, business registration number, and the jurisdiction in which it is registered.

Filing the information

A copy of this letter and all subsequent correspondence will be placed on the public record of the above-noted file. RingCentral may designate certain information contained in its response as confidential.Footnote 3

Please note that failure to provide the information requested above may result in serious consequences. The Commission may issue a mandatory order, which can be registered with the Federal Court, and failure to comply with a decision registered with the Federal Court could result in contempt of court proceedings.Footnote 4 The Commission may also initiate proceedings for disconnection of the company’s services in Canada.

The information requested above can be submitted electronically through the Commission’s website at www.crtc.gc.ca. Click on “Telecommunications Sector,” then choose either “File a document using My CRTC Account” or “Submit a telecom-related document online.”

Submissions should be addressed to

John Traversy
Secretary General
Canadian Radio-television and Telecommunications Commission
Ottawa, Ontario
K1A 0N2

The subject of your response letter should be “[Name of Your Company] Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration with the Commission ‒ File No.: 8663-C12-201015470.”

For additional information on the obligations, please follow the Service Providers’ section in this link: http://www.crtc.gc.ca/eng/telephone8.htm.

Sincerely,

Original signed by

Michel Murray
Director, Regulatory Implementation
Telecommunications Sector

c.c.: Dem Magmanlac, CRTC 819-953-6638, dem.magmanlac@crtc.gc.ca

Footnote 1

Local VoIP service providers are defined as service providers that (i) provide their customers with telephone numbers that conform to the North American Numbering Plan, (ii) provide access to and from the public switched telephone network, and (iii) enable customers to make and/or receive calls that originate and terminate within an exchange or local calling area. See: Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005.

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Footnote 2

According to paragraphs 97 and 98 of Decision 2005-21, express consent may be taken to be given where the customer provides written consent; oral confirmation verified by an independent third party; electronic confirmation through the use of a toll-free number; electronic confirmation via the Internet; oral consent, where an audio recording of the consent is retained by the carrier; or consent through other methods, as long as an objective documented record of customer consent is created by the customer or by an independent third party. To ensure that information regarding limitations on 9-1-1/E9-1-1 service is accessible to persons with visual disabilities, all customer notification, and any printed information used to secure the express customer consent, must be provided in alternative formats (e.g. Braille and large print), upon request.

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Footnote 3

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 Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, available on the Commission’s website at http://www.crtc.gc.ca/eng/archive/2010/2010-961.htm.

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Footnote 4

The Commission’s powers to request information from any person, issue mandatory orders, register its decisions with the Federal Court, and enforce the registered decision through the Federal Court, are set out in subsection 37(2), section 51, and subsection 63(2) of the Telecommunications Act, respectively.

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