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Telecom - Staff Letter addressed to Bell Canada and TELUS Communication Inc. (and your affiliates)

Ottawa, 12 October 2023

Reference: 8621-C12-01/08

BY E-MAIL

Bell Canada and TELUS Communication Inc. (and your affiliates)

Subject: Request for Information regarding Third-Party Call Centres’ Handling of Official Languages in the Event of a Default 9-1-1 Routed Call

Dear recipients,

In Telecom Regulatory Policy 2019-66, the Commission, among other things, directed Telecommunications Service Providers (TSPs) and Next Generation 9-1-1 (NG9-1-1)Footnote1 network providers to have arrangements in place for default 9-1-1 call routingFootnote2 with a third-party call centre.

When establishing these obligations, the Commission was not prescriptive with regard to service standards, including any pertaining to offering service in both official languages.

Staff notes that under section 26 of the Official Languages Act aFootnote3, as a federal institution that regulates access to 9-1-1 (an activity that relates to the health, safety or security of members of the public), the CRTC has a duty to ensure, wherever it is reasonable to do so in the circumstances, that members of the public can obtain 9-1-1 services in both official languages:

In light of the above, and in order to better understand how default-routed 9-1-1 calls treated by third-party call centres are handled with respect to official languages, Commission staff requests that recipients provide the following information including all relevant details, rationale and any supporting information, by 23 October 2023.

  1. For each third-party call centre(s) with whom you and/or your affiliates have an agreement for the purpose of default routing NG9-1-1 calls to the appropriate Canadian PSAP (hereby referred to as “NG9-1-1 default call routing call centre(s)"), provide:
    1. Name of the NG9-1-1 default call routing call centre;
    2. Name, title, business mailing address, business e-mail, and business phone number of the Primary Point of Contact.
  2. Confirm the default answering language in which your NG9-1-1 default call routing call centre(s) answers 9-1-1 calls (e.g. English only greeting, French only greeting, bilingual English and French greeting).
  3. Confirm whether you (or your NG9-1-1 default call routing call centre(s)) track the official languages used by the callers whose 9-1-1 calls are treated by your NG9-1-1 default routing call centre(s)? If so, provide, for 2022:
    1. The total number of 9-1-1 calls made over your network that were routed to your NG9-1-1 default call routing call centre(s);
    2. The number of calls for which the caller initially communicated in English, regardless of whether the caller transitioned to another language throughout the call;
    3. The number of calls for which the caller initially communicated in French, regardless of whether the caller transitioned to another language throughout the call;
    4. The number of calls during which the caller was not provided service in the official language of their choice. Provide details as to why service was not provided in the caller’s official language of choice.
  4. For 9-1-1 calls that are routed to your NG9-1-1 default call routing centre(s), provide details on the following:
    1. The process by which callers request services in the official language other than the default answering language, if available (e.g. verbal request to live operator, automated phone menus, etc.);
    2. The options available to callers who require services in the official language other than the default answering language, if available (e.g. via an interpreter, by being transferred to a live operator proficient in the requested official language, etc.); and
    3. Once the caller requests services in the official language other than the default answering language, how quickly do callers access these services, if available?
  5. If applicable, provide a copy of any agreement(s), regulation(s), standard(s), guideline(s) and/or legislation that govern how your NG9-1-1 default call routing call centre(s) handle(s) requests from 9-1-1 callers to be served in an official language other than your NG9-1-1 default call routing call centre(s) default answering language.
  6. Identify any other languages, in addition to French and English, supported by your NG9-1-1 default call routing call centre(s).
  7. How do(es) your NG9-1-1 default call routing call centre(s) treat calls received in an indigenous language?
  8. Provide details on any challenges callers and/or your third-party call centre(s) operators face when a caller’s official language of choice is not your third-party call centre’s default answering language?
  9. Provide details on any particular challenges or impacts you and/or your NG9-1-1 default call routing call centre(s) may experience should regulatory obligations be imposed to ensure that all callers whose 9-1-1 calls through NG9-1-1 default call routing call centres can receive services of equal quality in both official languages.
  10. Provide any additional details relevant to the Commission having a complete understanding of the process of receiving default-routed 9-1-1 calls in both official languages and the treatment of the calls by NG9-1-1 default call routing call centres not already covered by the above questions.

Please note that this letter and all responses received will be placed on a public record and will inform the Commission’s next steps as it considers the provision of access to emergency services in both official languages.  Pursuant to section 37 of the Telecommunications Act, the Commission may require Canadian carriers, or any other person, to submit information that is necessary for the administration of the Telecommunications Act.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, recipients may designate certain information as confidential though must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, should recipients designate information as confidential, recipients must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

The Commission requires all documents to be submitted electronically by using the secured service “My CRTC Account” Partner Log In or GCKey and filing the “Telecom Cover Page” located on that web page.

Yours Sincerely,

Original signed by Philippe Nadeau for

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.: Etienne Robelin, Manager, Emergency Services Policy, CRTC (etienne.robelin@crtc.gc.ca)

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