Telecom - Commission Letter addressed to Paul Beaudry (Cogeco Communications)
Ottawa, 12 July 2021
Our reference: 1011-NOC2018-0422
Vice-President, Regulatory Affairs
RE: Internet Code – 2021 Compliance Reports – Request for further information
This letter sets out follow-up questions about Cogeco’s compliance with the Internet Code. Footnote1
On July 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 1 October 2020.
Commission staff has reviewed Cogeco’s report and considers that certain elements require further clarifications.
Therefore, Cogeco is asked to file answers to the attached questions no later than 30 July 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 email@example.com.
(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
“As such, even though the Critical Information Summary may exceed 2 pages using easily readable font (up to 3-4 pages), Cogeco ensures that it is clear, concise, complete and in plain language, for the benefit of the customers.” (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.
Rule B.5.i.n.6. of the Internet Code states that
“Contracts must set out all the information listed below in a clear manner (items a-n): […] where customers can find information about how to make a complaint about Internet services, including contact information for the CCTS.”
In the sample contract you have provided with your 2020 Internet Code Compliance Report, it appears that this information is not included in your service agreement. Staff notes that this information is presented in the sample Critical Information Summary you have submitted, but reminds Cogeco that rule C.1.ii. of the Internet Code states that
“The Critical Information Summary may be provided as a separate document from the written contract or prominently as the first pages of the written contract. In either case, the information provided in the Critical Information Summary does not replace or fulfill any requirements to provide the same or similar information within the actual written contract.” (our emphasis)
Please address how the sample contract you have provided complies with rule B.5.i.n.6. of the Internet Code. Further, address any plans you may have to come into compliance with this rule.
Q3. Services for individuals who self-identify as having a disability.
In an attachment you filed in confidence you appeared to indicate to your customer service representative to not “offer these services to disabled customers. Only upon inquiry.”
Rule G.2.ii. of the Internet Code states that
“If a customer self-identifies as a person with a disability, the service provider must offer an extended trial period lasting a minimum of 30 calendar days to enable the customer to determine whether the service meets their needs.” (our emphasis)
Please address whether your training material is directing your customer service representatives to not inform consumers about a protection they should have under the Internet Code prior to them specifically inquiring about it.
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