Telecom Procedural Letter Addressed to Distribution List
Ottawa, 29 June 2018
Our reference: 8620-P8-201711630
Subject: Request for Information re: Part 1 Application by the Public Interest Advocacy Center (PIAC) in regards to Device Unlocking
Dear Sir or Madam,
On December 6 2017, PIAC submitted a Part 1 application asking that the Commission clarify elements of the Wireless Code related to the unlocking of mobile wireless devices. Specifically, PIAC asked the Commission to clarify rule F.1.(ii) such that ALL devices purchased prior to 1 December 2017 that are locked to a given WSP’s network should be unlocked upon request by that WSP, at no cost, regardless of whether the device owner currently has, previously had or never had an active account with the WSP.
In its application, PIAC expressed concern that wireless service providers (WSPs) refusing, for various reasons, to unlock phones locked to their network might result in, among other things, a reduction in market dynamism and a decrease in second-hand device options.
Commission staff has reviewed the application, interventions and reply, and considers that additional information is required on the record of the proceeding, including from WSPs who have not yet participated in the proceeding.
As a result, the WSPs listed in the distribution list attached are required to provide the information requested below. Companies that operate flanker brandsFootnote1 must file separate responses on behalf of these brands in addition to their primary brandsFootnote2:
- Provide the number of unlocking requests received, per month, since December 2017, where those numbers are available. Indicate in your response what proportion of such requests were denied, as well as the reasons for the denials. What trends, if any, do you see in the requests for device unlocks since the initial month of the unlocking rule’s coming into force?
- What are your current unlocking practices with respect to the following:
- devices from current customers (regardless of contract type);
- devices from your former customers; and
- devices from individuals or small businesses who never were your customers.
- Describe the training you provide your customer service representatives with respect to unlocking.
Responses to the request for information are to be filed with the Commission, and served on all parties to this proceeding by 30 July 2018. All submissions are to be received, and not merely sent, by that date.
Any WSP required to respond to this letter who has not previously participated in the proceeding will be considered a party to this proceeding going forward.
Accordingly, Commission staff considers it appropriate to provide all parties to the proceeding an additional opportunity to comment in a second phase of interventions, as well as to provide PIAC with the opportunity to file a final reply. Parties may file their comments by no later than 9 August 2018. PIAC may file its final reply by no later than 20 August 2018. The purpose of this additional comment period is to allow parties to comment on the new data filed in response to this request for information. If a party wishes to comment on something beyond this new data, it should provide clear rationale as to why this is required.
A copy of this letter and all related correspondence will be added to the public record of the proceeding.
If you have any questions, please contact Rémi Savard, Analyst, Social and Consumer Policy, at 819 997-4439 or firstname.lastname@example.org.
[Original signed by]
Director, Social and Consumer Policy
Consumer Affairs and Strategic Policy
c.c.: email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org
Brooke Telecom, email@example.com
Bruce Telecom, firstname.lastname@example.org; email@example.com
Freedom Mobile, Regulatory@sjrb.ca
Hay Communications, firstname.lastname@example.org
Huron Telecommunications, email@example.com
Ice Wireless, firstname.lastname@example.org
Mornington Communications, email@example.com
Petro-Canada Mobility, firstname.lastname@example.org; email@example.com
SSi Micro, firstname.lastname@example.org
Tuckersmith Communications, email@example.com
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