Telecom and Broadcasting - Staff Letter addressed to Mélanie Cardin (Québecor Média inc.)
Ottawa, 27 March 2024
Reference(s): 1011-NOC2020-0081
BY EMAIL
Mélanie Cardin
Director, Regulatory Affairs
Telecommunications
Québecor Média inc.
612 St-Jacques Street, 15th floor
Montréal, Quebec H3C 4M8
regaffairs@quebecor.com
Subject: Telecom and Broadcasting Decision CRTC 2022-28, When and how communications service providers must provide paper bills – Request for additional information
Dear Ms. Cardin:
This request for informationconcerns your Helix service subscribers.
Background
According to our information, it appears that the implementation of your new billing system, which would easily allow recurring paper billing for your Helix customers who requested it, has still not been completed, nearly two years after the beginning of the project.
The complaints and comments received by the Commission argue that it is also difficult, or even impossible, for some of your customers who are part of the three groups identified by Telecom and Broadcasting Decision CRTC 2022-28 (the policy) to obtain paper bills upon request. It is alleged that this option is not offered or recognized by your customer service representatives, including your door-to-door sales representatives.
Paragraph 90 of the policy specifies that:
90. “To ensure that this targeted safeguard protects the interests of subscribers in their relationships with providers and permits them to participate in the communications system on an equitable basis, customers eligible to receive paper bills must know their rights and be able to act on them without unreasonable or unnecessary barriers. In other words, those who are eligible must be able to request and obtain the paper bills to which they are entitled in a simple and direct manner; they must have an effective mechanism to make their choice known.” (Our emphasis)
Paragraphs 114 and 115 of the policy state that:
114. “The Commission considers that all service providers must be required to adhere to the requirements set out in this decision at paragraphs 86 and 105. It would not adequately further the policy objectives to offer vulnerable consumers these protections in their dealings with certain service providers only. This is also consistent with the current obligation to provide accessible bills to people with a visual disability, including people who are blind, which applies to all providers of telecommunications services (carriers, including wireless carriers, and TSPs), regardless of size.” (Our emphasis)
115. “For greater clarity, all of the requirements set out in this decision apply irrespective of the brand through which a CSP provides service. To restrict the requirements to certain brands would be to risk them not achieving their purpose.” (Our emphasis)
Consequently, let us remind you that the policy requires paper billing upon request for the three groups identified for all service providers irrespective of the brand through which the SP provides services. Commission staff reminds you that this includes Videotron and Helix.
With this in mind, please confirm:
- The precise date of implementation of your new billing system, which easily allows recurring paper billing following a request for your Helix platform.
- In accordance with paragraph 105.a. of the policy, the method(s) used to inform your current and future Helix customers of the availability of paper billing for those who are part of the three groups identified by the policy.
- That, in accordance with paragraph 105.c. of the policy, all your customer service representatives, including your door-to-door sales representatives, will, from now on, inform the three groups identified by the policy of the availability of paper billing.
Please provide the requested information by 15 April 2024 at the latest.
Your response will be placed on public record 1011-NOC2020-0081. As indicated in Broadcasting and Telecom Information Bulletin CRTC 2010-961, entitled Procedures for filing confidential information and requesting its disclosure in Commission proceedings, people can designate some information as confidential.
If you have any questions, please contact Patrick Arseneau, Senior Analyst, Social and Consumer Policy, at 819-994-7993 or patrick.arseneau@crtc.gc.ca.
Sincerely,
Original signed by
Nanao Kachi
Director
Social and Consumer Policy, Consumer, Research and Communications
- Date modified: