Telecom - Staff Letter addressed to Zachary Alaoui (Innovation, Science and Economic Development (ISED))
Ottawa-Gatineau, 3 February 2025
Reference: 8000-P114-202404929
BY EMAIL
Zachary Alaoui
Director General
Connected Canada Branch
Innovation, Science and Economic Development (ISED)
zachary.alaoui@ised-isde.gc.ca
Subject: Request for Information regarding an application by the British Columbia Ministry of Citizen’s Services
The CRTC has received an application from the British Columbia Ministry of Citizens' Services (the BC Ministry) requesting, among other things:
- that the complete internet and mobile wireless service provider facilities data sets designated as confidential in accordance with section 39(1) of the Telecommunications Act be shared or permitted to be shared through Innovation, Science and Economic Development Canada’s (ISED) broadband mapping team with the BC Ministry on a confidential basis. These data sets would include data provided in forms 256 (broadband), 267 (transport), and 278 (mobile) such as geospatial coverage addresses, speeds, and technologies;
- that transport data designated as confidential in accordance with section 39(1) of the Telecommunications Act, including by geospatial coverage addresses and geospatial coordinates where available, be shared or permitted to be shared through ISED’s broadband mapping team with the BC Ministry on a confidential basis.
The BC Ministry indicated that it intends to use this data to support existing and future connectivity contribution programs.
The CRTC is seeking certain information on ISED’s approach to the storage and protection of confidential data to add to the public record of this proceeding, which can be found at 8000-P114-202404929. As part of this proceeding, TSPs have raised concerns highlighting the importance of safeguards such as Non-Disclosure Agreements (NDAs) and controlled access to ensure the confidentiality of the data provided. The information requested below will assist the CRTC in making determinations on the application.
Questions for ISED:
- Restricted Access and Security Measures:
- Some TSPs have indicated their willingness to share sensitive data if sufficient safeguards, such as Non-Disclosure Agreements (NDAs), are in place. Does ISED currently incorporate NDAs in its data-handling processes?
- If NDAs or equivalent measures are not currently in place, could ISED adopt such safeguards to address confidentiality concerns regarding the sharing of confidential data collected in the Annual Facilities Survey with provincial and territorial governments?
- Sharing of Data:
- What measures does ISED currently have in place to protect the sharing of confidential data? Additionally, what measures would ISED put in place and implement to protect confidential data and implement access and version controls to ensure secure data sharing of the confidential data collected in the Annual Facilities Survey with provincial and territorial governments?
ISED is asked to submit its responses to this request for information by 28 February 2025.
All parties can submit comments on the responses provided by ISED no later than 14 March 2025. All comments filed must be received, not merely sent, by the date provided.
All related correspondence will be public. 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, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation for 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, a person designating information as confidential 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. If filing confidential information, the Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover Page” located on the Commission’s website.
If you have any questions pertaining to this letter, please contact Bartek Bober by phone at (819) 230-0725 or by email at: bartek.bober@crtc.gc.ca.
Thank you, in advance, for your cooperation.
Sincerely,
Mark Allen
Senior Manager, Market Intelligence
Consumer, Analytics, and Strategy
Bartek Bober, bartek.bober@crtc.gc.ca
Tom Blackwood, tblackw5@gmail.com
Tony Giligan, tony.gilligan@ecomm911.ca
Susan Church, susan.church@blueskyregion.ca
Ben Arril, ben.arril@gov.bc.ca
Cheryl Hansen, claude.innes@gnb.ca
Pierre Desmarteau, Pierre.Desmarteau@mce.gouv.qc.ca
Stefanie Corbett, lmacmillan@gov.pe.ca
LeBourdais, Maureen A, mlebourdais@cariboord.ca
Michael Riis-Christianson, michael.riischristianson@rdbn.bc.ca
Panneton Valérie, vpanneton@ctal.ca
Jonathan Veale, jonathan.veale@novascotia.ca
Rob Gay, rob11gay@gmail.com
Susan Clovechok, director.clovechok@rdek.bc.ca
Adela Wan, adela.wan@ontario.ca
Andrea Newell, anewell@houston.ca
Roel Coert, roel.coert@i-valley.ca
Owen Torgerson, otorgerson@valemount.ca
Walter Popoff, wpopoff@rdck.bc.ca
Nellie Davis, nellie.davis@rdbn.bc.ca
Ben Campbell, ben@northerndevelopment.bc.ca
Martin Elphee, district@fortstjames.ca
Reiko Tagami, rtagami@ubcm.ca
Warren Noga, warren@rmalberta.com
Johanna Helbig, jhelbig@coastalfirstnations.ca
Neil Smellie, neil@canwisp.ca
Judy Greenaway, judy.greenaway@rdbn.bc.ca
Michael McNally, mmcnally@ualberta.ca
Byron Holland, byron.holland@cira.ca
Bill Payne, bill.payne@haltonpolice.ca
Philippe Gauvin, bell.regulatory@bell.ca
Imran Mohiuddin, imran.mohiuddin@cybera.ca
Richard Bates, richard.bates@gov.ab.ca
Steve Mark, smark@icisociety.ca
Rob McMahon, info@firstmile.ca
Marielle Wilson, regulatory.matters@corp.eastlink.ca
Geoffrey (Geoff) White, gwhite@piac.ca
Andy Kaplan-Myrth, regulatory@teksavvy.ca
Jonathan Holmes, jonathan.holmes@itpa.ca
Kevin Spelay, document.control@sasktel.com
Howard Slawner, regulatory@rci.rogers.com
Cindy Wallace, cindy.wallace@xplore.ca
Erin Ruttan, erin.ruttan@calgary.ca
Kim Miller, kim.miller@telus.com
Melanie Cardin, regaffairs@quebecor.com
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