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Telecom - Staff Letter addressed to Simon-Pierre Olivier (Rogers Communications Canada Inc.)

Ottawa, 22 January 2024

Our reference: 8000-C12-202306407

BY EMAIL

Simon-Pierre Olivier
Director, Regulations and Economics
Rogers Communications Canada Inc.
333 Bloor St East
Toronto, ON M4W 1G9

regulatory@rci.rogers.com

Subject: Request for information regarding access to French language services during a 9-1-1 call

Dear Simon-Pierre Olivier,

Commission staff was recently informed of an event that occurred on 29 December 2023, in which an individual’s 9-1-1 call from a mobile device on the Rogers Communications Canada Inc. (Rogers) mobile network was delivered to Northern911, a third-party call center employed to confirm the caller’s location and manually route the 9-1-1 call to the appropriate Public Service Answering Point (PSAP). According to a news article published in La Presse on this matter,Footnote1 the Northern911 call taker answering the call was unable to communicate with the caller in French despite the caller’s official language of choice being French.

The Canadian public and the Commission place a high degree of importance on being able to access timely and effective 9-1-1 services, including the ability for Canadians to be answered and communicate details related to their emergency in their preferred official language. As such, and in accordance with section 37 of the Telecommunications Act, Rogers is required to provide comprehensive answers to the questions set out below, including all relevant details, rationale and any supporting information, by 2 February 2024.

  1. Describe the complete sequence of events related to the incident covered by the article in La Presse, clearly indicating, in sequence, the details of the routing of the relevant call(s) (including location), and any role played by Rogers and any third party, including the third-party call center employed by Rogers for the purpose of having the location of 9-1-1 calls manually determined for the purpose of routing to the appropriate PSAP (hereafter referred to as “third-party call center”).
  2. Confirm where the third-party call centre routed the call. If the call was routed to a PSAP, indicate which one, confirm whether and how it was determined that this was the appropriate PSAP to direct the call to, and if it was. If it was not routed to a PSAP, explain why.
  3. Provide details on the reasons for which the call was routed through a third-party call centre and not directly to a PSAP responsible for providing service to the area from which the call was being made.
  4. Confirm the name of the third-party call centre involved in the event in question and provide a copy of the service agreement or contract outlining its responsibilities to Rogers relative to the processing and routing of 9-1-1 calls to PSAPs.
  5. Provide details on any existing provisions in the service agreement between Rogers and its third-party call centre regarding the provision of French language or bilingual services by its third-party call centre to 9-1-1 callers.
  6. Provide details on any options provided by Rogers whereby its customers can select upon subscription or modify thereafter their preferred language of communication, including whether this selection applies to 9-1-1 calls treated by third-party call centres, whether, how, and when this information is relayed to the third-party call centre, how Rogers ensures that the customer’s preference is respected, and what happens if the customer does not indicate a preference.
  7. Explain whether, according to Rogers, there has been any breach of the terms of the service agreement between the third-party call centre and Rogers, particularly regarding the provision of French language services in the context of the events described in the news articles.
  8. If the service agreement does not provide for the provision of call processing services in French or in both official languages, please explain why.
  9. Provide details of any communication Rogers has had with its third-party call center in relation to this event, including the relevant dates and nature of the exchanges. 
  10. Confirm and describe the means through which callers using Rogers’ mobile service to make 9-1-1 calls can access services in the official language of the caller’s choice when connected to the third-party call center employed by Rogers in events such as the one described in the La Presse article. Provide the list of means in order of precedence (primary, alternate, tertiary, etc.) as well as an explanation of the circumstances in which one means is leveraged over the other(s). 
  11. Explain, if applicable, why any such means described at question 10 were not used during the event in question, resulting in the inability of the caller to communicate with the operator of the third-party call center in French. If such means were used, explain why the caller was unable to obtain services in French.
  12. Explain, if any, what actions or measures Rogers has taken and/or intends to take to avoid this situation being repeated in the future. For each action or measure, specify the steps and relevant dates and timelines.
  13. Provide any additional details or information relevant to the Commission having a complete understanding of the situation not already covered by the above questions, including but not limited to,
    1. any recordings or transcripts of the 9-1-1 call in question which Rogers would have in its possession; and
    2. statistics pertaining to the number of 9-1-1 calls that are directed to third-party calls centres as the first point of contact relative to the total number of 9-1-1 calls treated by the Rogers mobile network and delivered directly to the appropriate PSAP.

This letter and any subsequent correspondence will be placed on the CRTC’s website. 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, Rogers 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 Rogers designate information as confidential, Rogers 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.

Note that, in accordance with its normal practices, the Commission may disclose or require the disclosure of information designated as confidential if it determines that its disclosure is in the public interest, i.e., where the specific direct harm does not outweigh the public interest in disclosure.

Considering the public interest in understanding what happened in this specific event, Commission staff expects Rogers to disclose information to the maximum extent possible.

Where a document is to be filed, the document must be 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

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.: Étienne Robelin, Manager, Emergency Services, CRTC, Étienne.robelin@crtc.gc.ca

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