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Telecom - Staff Letter addressed to the Distribution List

Ottawa, 25 July 2024

Our reference: 1011-NOC2018-0422

BY EMAIL

Distribution List

Subject: Internet Code – 2024 Compliance Reports

This letter sets out the specific questions you are to answer in your 2024 Internet Code Compliance Report. Your report is due by 3 September 2024.

Context

The Internet Code is a mandatory code of conduct for providers of retail fixed Internet access services provided to individuals (Internet services). The Internet Code took effect on 31 January 2020. The Internet Code applies in full to all renewed, amended, or extended contracts. Certain provisions related to the clarity of communication also apply to existing contracts.

Requirement to submit annual reports

As set out in paragraph 480 of the Internet Code Policy:

“480… the Commission also directs the ISPs subject to the Internet Code to report annually to the Commission, by 31 August, to demonstrate that they have implemented the Code effectively and on time, and describe how they are ensuring that their customer service representatives are knowledgeable about both the ISPs’ and customers’ rights and responsibilities under the Code, including those specifically related to Canadians with disabilities; retain statistics on an ongoing basis on how many customers, out of the total number of customers who make a formal complaint, were informed about the CCTS and provide these statistics to the Commission as part of their compliance reports; …”

Questions to answer in compliance reports due on 3 September 2024

In light of the above, this letter sets out questions that each ISP must answer when submitting their 2024 Internet Code Compliance Report.

Companies that operate flanker brands must file responses on behalf of these brands in addition to their primary brands.

Procedures for filing

As set out in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin 2010-961, 23 December 2010, as amended, ISPs may designate certain information as confidential.

ISPs must provide an abridged version of the document involved, accompanied by detailed rationale to explain why the disclosure of the information is not in the public interest.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

Yours sincerely,

Original signed by

Nanao Kachi
Director, Social and Consumer Policy

cc:
Guillaume Leclerc, Senior Policy Analyst, CRTC, guillaume.leclerc@crtc.gc.ca

Distribution List:

bell.regulatory@bell.ca;
reglementa@telebec.com;
Regulatory.Matters@corp.eastlink.ca;
telecom.regulatory@cogeco.com;
regaffairs@quebecor.com;
melanie.cardin@quebecor.com;
rwi_gr@rci.rogers.com;
ruth.altman@rci.rogers.com;
document.control@sasktel.com;
regulatory.affairs@telus.com;
regulatory@sjrb.ca;
regulatoryaffairs@nwtel.ca;
Xplornet.Legal@corp.xplornet.com;

Appendix

Q1. Self-reported compliance with the Internet Code

Fill out the following chart to provide your self-assessment of compliance with each requirement set out in the Internet Code.

Requirement Do you consider that you are currently meeting this requirement? (Answer Yes or No)
  • If you do not consider that you are currently meeting this requirement, explain why and provide your plan to come into compliance.
Preamble
1. i. Interpretation a.    
b.    
c.    
1. ii. Interpretation    
2. i. Retaining evidence    
A. Clarity
1. Clear communication i.    
ii.    
2. Prices i.    
ii.    
3. Unlimited services i.    
ii.    
B. Contracts and related documents
1. Provision of contract i.    
ii. a. or b.    
2. i. Cancellation period when the permanent contract conflicts with the customer’s agreement    
3. i. When a customer requests a copy of their contract 1.    
2.    
4. i. Accessible formats    
5. i. Content of contracts Key contract terms and conditions
a.    
b.1.(a) or (b)    
b.2. (a) or (b)    
c.    
d. 1. to 5.    
e. 1. and 2.    
Other aspects of the contract
f.    
g.    
h.    
i.    
j.    
k.    
l.    
m.    
n. 1. to 7.    
C. Critical Information Summary
1. General i.    
ii.    
iii. a. to f.    
iv. a. and b.    
v.    
D. Changes to contracts and related documents
1. Changes to key contract terms and conditions during the commitment period i.    
ii.    
iii. a. or b.    
2. i. Changes to key contract terms and conditions after the commitment period    
3. Changes to other contract terms and conditions or related documents i.    
ii.    
4. Information that must be disclosed during offers to change existing contracts i. a. and b.    
E. Bill management
1. Notification – Usage limit i.    
ii.    
2. Data monitoring tools i.    
ii.    
3. i. Notification – Data overage charges    
F. Equipment issues
1. Service calls, including visits to residences for installation and repairs i.    
ii.    
iii.    
2. i. Service outages      
G. Contract cancellation and extension
1. Early cancellation fees – General i.    
ii. a.    
ii. b.
iii. a.    
iii. b.    
iv. a. to c.    
2. Trial period i.    
ii.    
iii.    
iv.    
v. a. and b.    
3. Cancellation date i.    
ii.    
4. Refunds for prepaid services not provided following cancellation i.    
ii.    
5. Contract extension i.    
ii. a. to c.    
H. Security deposits
1. Requesting, reviewing and returning a security deposit i. a. to e.    
ii.    
iii.    
I. Disconnection
1. When disconnection may occur i. a., b., or c.    
ii.    
iii.    
iv. a. to c.    
2. Notice before disconnection i. a., b., or c.    
ii. a. to e.    
iii. a., b., or c.    
iv.    
v.    
3. i. Disputing the reasons for disconnection a.    
b.    
c.    

Q2. Sample Internet service contracts and related documents

In order to assess the content of each ISP’s contracts and related documents and the extent to which they demonstrate compliance with all provisions of the Internet Code, provide the following:

  1. A copy of a sample Internet service contract;
  2. A critical information summary (CIS) for that contract; and
  3. Other related documents that apply to the contract, including terms of service, fair use policies, and privacy policies.

Confirm whether these documents have been significantly modified since your 2023 compliance reports. If so, how.

Q3. Training for customer service representatives

In order to assess the actions each ISP has taken to ensure that their customer service representatives are knowledgeable about both ISPs’ and customers’ rights and responsibilities under the Internet Code, including those specifically related to Canadians with disabilities, provide the following:

  1. An overview of the actions you have taken since your 2023 compliance reports (31 August 2023) to further ensure your customer service representatives are
    1. knowledgeable about ISPs’ and customers’ rights and responsibilities under the Internet Code and able to describe the Internet Code’s provisions;
    2. knowledgeable about ISPs’ and customers’ rights and responsibilities under the Internet Code and able to describe the Internet Code’s provisions that are especially relevant for Canadians with disabilities (e.g. accessible formats, extended trial periods, and availability of sign language videos); and
    3. able to explain recourse options for customers.
  2. Supporting documents as relevant.

Q4. Statistics on complaints escalated to the Commission for Complaints for Telecom-Television Services (CCTS)

As set out in the Internet Code Policy, you must “retain statistics on an ongoing basis on how many customers, out of the total number of customers who make a formal complaint, were informed about the CCTS and provide these statistics to the Commission as part of [the] compliance reports;”

For the period from 1 August 2023 to 30 June 2024, provide the following information:

  1. Explain how you define “formal complaint” in the context of Internet services and how this definition may have changed since your 2023 compliance reports. For clarity, provide a brief example of a formal complaint and an informal complaint.
  2. How many customers made a formal complaint to you about the Internet services subject to the Internet Code
  3. How many of these customers (# and %) were informed about the CCTS during the formal complaint process?

If you cannot provide information for the entirety of that timeframe, explain why and provide supporting rationale.

Q5. Internet Code information on ISP websites

  1. Describe how you provide prominent links to the Internet Code on your websites, including on the home page and on all pages on which your Internet service plans and offerings are described and provide screen captures. Confirm whether your approach has changed since your 2023 compliance reports.
  2. Provide links to the ASL and LSQ videos on your website(s) that (i) promote awareness of the Internet Code and associated rights, (ii) explain terminology that is commonly used in Internet service contracts, and (iii) inform customers about methods to manage data consumption and the typical amount of data required for common Internet activities. Provide relevant screen captures.

Q6. Internet Code information in ISP stores and kiosks

Provide an example of the information you visually display of the Internet Code-related information that must be available in your stores and kiosks. Confirm whether your approach has changed since your 2023 compliance reports.

Q7. Internet Code bill statement notification

Provide a copy of the notification regarding the Internet Code you were required to add to your customers’ bill statements on a semi-annual basis and the dates these were included. Confirm whether your approach has changed since your 2023 compliance reports.

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