Telecom Commission Letter addressed to Philippe Gauvin (Bell Canada)
Ottawa, 12 July 2021
Our reference: 1011-NOC2018-0422
Mr. Philippe Gauvin
Assistant General Counsel
RE: Internet Code – 2021 Compliance Reports – Request for further information
This letter sets out follow-up questions about the compliance of Bell Aliant, Cablevision, DMTS, KMTS, Maskatel, NorthernTel (including NorthernTel FibreOp), Northwestel, Ontera, Télébec and Virgin Mobile Canada (Virgin) (collectively Bell), with the Internet Code. Footnote1
On July 14 2020, Commission staff sent a letter, titled Internet Code – 2020 Compliance Reports, Footnote2 which set out specific questions for Internet service providers to answer in their compliance reports for the Internet Code. These reports were due by October 1, 2020.
Commission staff has reviewed Bell’s report and considers that certain elements require further clarifications.
Therefore, Bell is asked to file answers to the attached questions no later than July 30, 2021.
As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, service providers may designate certain information as confidential. Service providers 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 service providers’ compliance with the Internet 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 Guillaume Leclerc, Senior Policy Analyst, Social and Consumer Policy, at firstname.lastname@example.org.
(Original signed by)
Director, Social and Consumer Policy
Appendix – Questions
Q1. Critical Information Summary (CIS)
In your 2020 Internet Code Compliance Report, you noted that
“We provide a Critical Information Summary that is clear and concise, uses plain language and is in an easily readable font and format. However, we note that in some cases, depending on the services ordered (and required disclosure), a Critical Information Summary may exceed two pages because of the system rules for formatting and the insertion of page breaks.” (our emphasis)
Rule C.1.iv.b. of the Internet Code states that
“A service provider must ensure that the Critical Information Summary is clear and concise (does not exceed two pages), uses plain language, and is in an easily readable font.” (our emphasis)
Please address how having a CIS exceeding two pages meets the requirement that the CIS be concise. Further, address any plans you may have to come into compliance with this rule.
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