Telecom Commission Letter Addressed to Philippe Gauvin (Bell Mobility Inc.)

Ottawa, 27 September 2018

Our reference:  1011-NOC2016-0293

BY E-MAIL

Philippe Gauvin
Assistant General Counsel
Bell Mobility Inc.
bell.regulatory@bell.ca

RE: Revised Wireless Code Implementation – 2018 Compliance Reports – Request for further information File No. 1011-NOC2016-0293

Dear Mr. Gauvin,

This letter sets out follow-up questions about Bell’s compliance with the revised Wireless CodeFootnote1

On 15 February 2018, Commission staff sent a letter, titled Revised Wireless Code Implementation – Compliance Reports,which set out specific questions for wireless service providers to answer in their compliance reports for the revised Wireless Code. These reports were due by 31 March 2018.

Commission staff has reviewed Bell’s report, dated 29 March 2018, and considers that certain elements require further clarification.

Therefore, Bell is asked to file answers to the attached questions about its compliance report by no later than 9 October 2018.

As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, WSPs may designate certain information as confidential. WSPs 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.

These materials may be incorporated into the record of a potential future proceeding evaluating WSP compliance with the revised Wireless Code and assessing whether remedial measures are appropriate in the circumstances.

For further information on how to submit your response, see the CRTC’s web page Submitting applications and other documents to the CRTC using My CRTC Account. If you have any questions, please contact Meghan Wawryk, Senior Analyst, Social and Consumer Policy, at 819 635-6959 or meghan.wawryk@crtc.gc.ca.

Yours sincerely,

(Original signed by)

Scott Shortliffe
Chief Consumer Officer, Consumer Affairs and Strategic Policy
CRTC

Enclosure

Questions

  1. Clicking on the “mobility” sections of NorthernTel and Télébec’s websites brings the user directly to Bell Mobility’s website.  Please confirm whether NorthernTel and Télébec’s wireless customers are provided with Bell Mobility’s contracts, terms and conditions, and other related documents.
  2. In the Commission staff letter dated 15 February 2018, question 5.c. asked wireless service providers to “Provide an example of the text used and describe the delivery method(s) you employ when seeking consent from the account holder or an authorized user to pay additional charges beyond the $100 of national and international data roaming charges within a single billing cycle.” (Emphasis added)

    Bell did not provide an example of the message sent to an account holder or authorized user when seeking consent to go beyond the $100 data roaming cap. Instead, Bell provided an example of the notification that is sent to the device user, which may or may not be the account holder or an authorized user.

    If the notification to the account holder or authorized user differs, submit an example of this text and describe the delivery method(s) employed when seeking consent from the account holder or authorized user.

  3. In the Commission staff letter, dated 15 February 2018, wireless service providers were directed to provide copies of the documents they provide to customers entering wireless contracts, including:
    • A copy of an example contract;
    • A critical information summary (CIS) for that contract; and
    • Other related documents that apply to the contract, including terms of service, fair use policies, and privacy policies.

    Section B.1 (Postpaid service contracts) iii. a. of the revised Wireless Code requires that “Contracts for postpaid services must set out all the information listed below in a clear manner (items a-m): a. the services included in the contract, such as voice, text and data services, that the customer agreed to upon entering into the contract and will receive for the duration of the contract, and any limits on the use of those services that could trigger overage charges or additional fees”.

    1. Please review the “Your Rate Plan Details” sections of the sample postpaid contract and CIS provided by Bell Mobility and explain, in detail, why and how Bell considers that the amount of monthly data included in the customer’s plan is listed in a clear manner. If data is not included in the plan described in the sample postpaid contract and CIS, provide an example of a contract and CIS based on a plan with data.
    2. Similarly, please review the sample CIS provided for Bell MTS, and explain, in detail, why and how Bell considers that the amount of monthly data included in the customer’s plan to be “listed in a clear manner.”
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