Telecom Commission Letter addressed to Philippe Gauvin (Bell Canada) and the Distribution List

Ottawa, 16 August 2019

Our reference:  8638-B2-201905879

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 19, 160 Elgin Street
Ottawa, Ontario, K2P 2C4
bell.regulatory@bell.ca

Distribution list

RE:   Part 1 Application by Bell Canada to allow Bell Canada and its affiliates to temporarily block certain potential verified fraudulent and scam voice calls on trial basis File No. 8638-B2-201905879 – Requests for information – Abridged version

Dear Mr. Gauvin:

The Commission is in receipt of a Part 1 Application from Bell Canada on its own behalf and on behalf of all of its subsidiaries that carry voice traffic dated 24 July. In this application, Bell Canada requested the Commission's approval, pursuant to section 36 of the Act, to conduct a 90-day trial to block certain known, verified, fraudulent scam voice telephony calls received or transmitted from, to, or over its networks.

Attached in Appendix 1 are requests for information from Commission staff.

Responses to these requests for information are to be filed with the Commission no later than 6 September 2019

Sincerely,

(Original signed by)

Steven Harroun
Chief Compliance and Enforcement Officer, CRTC

cc. Confidential version to Bell Canada,

cc. Abridged version to Bell Canada, interested parties to CETNOC 2017-405, 2017-405-1 and other providers of voice telecommunication service

Appendix 1

A. Additional information on the proposal

In paragraph 9 of its submission, Bell Canada indicated that it will build upon the blocking tools being developed for the purpose of CETRP 2018-484, and combine them with artificial intelligence and machine learning to potentially block additional types of fraudulent and scam nuisance calling.

  1. In order to enable the Commission and the public to better understand the proposed blocking solution and therefore enable intervenors to provide meaningful comments on this proposed call blocking solution, provide a summary for the public record of how the proposed call blocking tool will block additional types of fraudulent and scam nuisance calling.
    1. #.
    2. b. #.
  2. Describe in detail the indicators or metrics that Bell Canada will apply to assess the success for this trial.
    1. Will the call blocking apply only to voice calls or also to text/sms messages?
    2. If texts/sms messages will also be blocked, describe in detail how the call blocking methodology would ensure that it does not capture Public Emergency messages?
    1. Explain in detail how Bell Canada will minimize or eliminate the potential blocking of calls that are “false positive” calls?
    2. What safeguards are there for legitimate informational Robocalls calls such as:
      • Flight being cancelled/delayed
      • Health Care providers (Doctor/Pharmacy) appointment reminders
      • Information about a delayed/cancelled school or school bus
      • Banks, Financial institutions, Debt collection agencies, Charities etc.
    3. Is there any intention to combine this technique with STIR/SHAKEN protocol in the future? If so, please elaborate.

B. Privacy concerns and impact on end-users

    1. Describe in detail  the privacy and data protection safeguards, if any, that will be in place for the data used to populate the AI programs and therefore for machine learning.
    2. Will the data collected for this trial be generated internally? Will it come from third parties?
    3. Will the data collected for this trial be used for other purposes?
    4. Are third-party databases used? If so, are these located in Canada?
  1. Will end-users have the right to:
    1. opt-out of having their call information used in the trial?
    2. opt-out of having their calls blocked? If so, how could this system work if they permit calls to opt-out
  2. Will subscribers have access to any information as to the number of blocked calls that were directed to their telephone numbers? If any such access will be provided, describe the type of information that would be made available and the process for subscribers obtaining access to such information.

C. Impact on other Telecommunications service providers

At paragraph 14 Bell Canada explained that the proposed new mechanism for blocking calls would impact all calls that transit or terminate on its network (i.e., even a call that originates internationally and is destined for another local exchange carrier (LEC) that is not its affiliate, but for which an interexchange carrier delivers the call to Bell Canada to transit for them to that LEC, would be blocked based on criteria submitted in confidence:

  1. Provide statistics showing estimated/potential percentage of calls that would be blocked under its proposal that would be destined to other Canadian TSPs that are not Bell Canada’s affiliates?
    1. Discuss in detail the potential technical and economic impacts that the proposed call blocking program could have on other TSPs that are not Bell Canada’s affiliates but whose calls would be transited or terminated on Bell Canada’s network.  In this discussion, refer in particular to the impacts that may result from (i) complaints concerning the blocking of legitimate calls generated from end-users of any such other TSPs; (ii)  potential technical manipulations that might required by such other TSPs to get the legitimate calls back, and (iii) decrease in revenues as a result of decrease in traffic.
    2. Indicate what measures are to be in place to prevent any negative impacts on other TSPs
    3. If negative impacts on other TSPs cannot be prevented, indicate what measures are to be in place to mitigate and minimize any negative impacts on other TSPs
  2. Has Bell Canada discussed the proposed solution with other TSPs?
    1. If so, provide a summary of the issues discuss and identify all concerns raised.  And,
    2. If not, does Bell Canada intend to engage in such discussions prior to implementation of the test, if the test is approved? 
    3. Or, explain why Bell Canada has not considered such discussions necessary.
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