ARCHIVED - Telecom Commission Letter Addressed to Distribution list
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Ottawa, 17 April 2015
File Number: 8665-P8-201400762
BY EMAIL
To: Distribution List
Subject: Public Interest Advocacy Centre and the Consumers’ Association of Canada’s applications regarding Bell’s use of customer information, CRTC file #8665-P8-201400762 – Requests for Information
Dear Sirs/Madam:
On 27 January 2014, the Commission received an application from the Public Interest Advocacy Centre and the Consumers’ Association of Canada, collectively PIAC/CAC, concerning the use of customer information by BCE Inc., Bell Canada, Bell Mobility Inc., and Bell Aliant Regional Communications, Limited Partnership, and their affiliates (collectively, Bell). PIAC/CAC raised concerns related to the Bell’s Relevant Ads Program (RAP). Bell filed its Answer on 30 March 2014.
On 19 June 2014 and 20 October 2014, staff sent a letter to the Bell Companies containing requests for information associated with the above-noted Part 1 application, responses to which were filed on 10 July 2014 and 04 December 2014 respectively, with unredacted versions of the 04 December 2014 response being filed by Bell on 12 January 2015.
The Office of the Privacy Commissioner of Canada (OPC) had also been investigating Bell’s use of customer information in RAP and on 7 April 2015, the OPC published the results of its investigation. In its report, the OPC noted that Bell has agreed to make a number of changes to RAP as follows:
- Bell has agreed to cease to using both credit rating information and full customer postal code. From now on, it will use only the first three characters of the postal code.
- By 30 April 2015, Bell will improve its RAP-related communications to explain more clearly the extent of the information that Bell may use for the RAP, now and in the future.
- By 31 March 2015, Bell will remove The Source from the list of affiliates with which Bell may share RAP information.
- Bell will exercise greater due diligence, in the form of contractual and other measures, to protect against the possibility that advertisers might, using other available information, link customer profile information to an identifiable individual.
- Bell will document and communication to staff, certain internal procedures to ensure the appropriate use of customers’ personal information.
The OPC also recommended that Bell implement an opt-in model to obtain consent, as opt-out was not adequate, though it noted at that time that Bell had not agreed to this recommendation. Commission staff notes that Bell has subsequently announced that it will abide by the OPC’s decision including the opt-in approach and a notice was published on the OPC’s website indicating that Bell has advised the OPC that it has decided to withdraw its Relevant Ads Program and that it will delete all existing customer profiles related to the program.
In order to ensure that the Commission’s record concerning Bell’s RAP is complete and current, Commission staff requests that Bell confirm that it has withdrawn the program, that it will delete all existing customer profiles related to the program, and that if it launches a similar program in the future, it would do so using express opt-in consent.
Bell response is to be filed with the Commission, serving copies on all other parties, by 21 April 2015.
Procedural information
This letter and all subsequent correspondence form part of a public record. As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person claiming confidentiality with respect to information submitted must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.
All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.
If you have any questions regarding this letter, please contact Antica Corner at 819-997-1334 or by email at antica.corner@crtc.gc.ca.
Yours sincerely,
Original signed by
Steven Harroun for
Nanao Kachi
Director, Social and Consumer Policy
Consumer Affairs and Strategic Policy
c.c.: John Lawford, PIAC jlawford@piac.ca
Bruce Cran, CAC bcranbiz@telus.net
Antica Corner, CRTC antica.corner@crtc.gc.ca
Marc Nanni, m_nanni@hushmail.com
Distribution List
Mr. Philippe Gauvin
Senior Counsel - Regulatory Law & Policy
Bell Canada
Floor 19, 160 Elgin Street
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca
Ms. Suzanne Morin
General Counsel – Regulatory & Privacy Chief
Bell Aliant Regional Communications L.P.
Floor 19, 160 Elgin Street
Ottawa, Ontario K2P 2C4
regulatory@bell.aliant.ca
Geoffrey White
Counsel for PIAC
Public Interest Advocacy Centre
1204 - 1 Nicholas Street
Ottawa, Ontario K1N 7B7
gwhite@piac.ca
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