Telecom - Commission Letter addressed to Marielle Wilson (Eastlink)

Ottawa, 12 July 2021

Our reference: 1011-NOC2018-0422


Marielle Wilson
Vice-President, Regulatory à

RE: Internet Code – 2021 Compliance Reports – Request for further information

Dear Marielle,

This letter sets out follow-up questions about Bragg Communications Inc.’s, carrying on business as Eastlink (Eastlink), compliance 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 1 October 2020.

Commission staff has reviewed Eastlink’s report and considers that certain elements require further clarifications.

Therefore, Eastlink 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

Yours sincerely,

(Original signed by)

Nanao Kachi
Director, Social and Consumer Policy

Appendix – Questions

Q1. Critical Information Summary (CIS)

In your 2020 Internet Code Compliance Report, you noted that

“Eastlink customers receive a critical information summary as part of the Welcome Email directly after the service agreement is agreed to which contains all of the required information as outlined in C.1.3. in a clear, easy to understand format.”

Staff notes that the sample email you have provided is seven pages long.

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.

Q2. Actions to ensure CSR are knowledgeable about the needs of Canadians with disabilities.

In your response to Q3.a.ii. of July 14, 2020, Commission staff letter, you were asked to provide

“An overview of the actions you have taken since the Internet Code Policy was published (July 2019) to ensure your customer service representatives are knowledgeable about ISPs’ and customers’ rights and responsibilities under the Code and able to describe the Code’s provisions that are especially relevant for Canadians with disabilities (e.g. accessible formats, extended trial periods, and availability of sign language videos)” (our emphasis)

It appears to staff that you have not addressed the actions that were specific to provisions that are especially relevant for Canadians with disabilities.

Please address the specific actions you have put in place to that end.

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