Category: North America

CRTC File: 8638-B2-201905879 Submission of the Internet Society Canada Chapter Who we are The Internet Society Canada Chapter (ISCC) is a not-for-profit corporation that engages on internet legal and policy issues to advocate for an open, accessible and affordable internet for Canadians. An open internet means one in which ideas and expression can be communicated and received except where limits have been imposed by law. An accessible internet is one where all persons and all interests can freely access websites that span all legal forms of expression. An affordable internet is one by which all Canadians can access internet services at a reasonable price. ISCC intervenes in this proceeding because the application by Bell Canada (“Bell”) raises serious concerns around both consumer privacy and open competition in the telecommunications market. ISCC is fully aware of the impact that fraudulent and nuisance calls have on Canadians and we applaud Bell Canada for taking steps beyond what is required in CETRP 2018-484 to address this serious issue. However, we have serious concerns with the part one application from Bell Canada for two major reasons – that Bell’s initiative will impact non-Bell customers and we have serious privacy concerns about the proposed Artificial Intelligence “AI” system which does not provide any way for Canadians to opt-out of its data collection. The operation of this system, and the criteria by which it will operate, are also shrouded in secrecy. Almost every detail of the application has been filed in confidence with the commission, making it virtually impossible for any third party to properly comment on this application. We also reaffirm our view that, in regard to customer data and privacy, explicit consent must be given before any subscriber data can be used in a system such as this. In the case of this part one application, if Bell is granted the ability to turn this system on, it should be done as an explicit opt-in system only for Bell subscribers and Bell should be required to disclose in plain English to consumers how their calling and location data are being utilized. Scope of the Application The scope of this application is our primary concern. In paragraph 14 of the application, Bell says that “this blocking would impact all calls that transit or terminate on our network (i.e., even a call that originates internationally and is destined for another local exchange carrier (LEC) that is not our affiliate, but for which an interexchange carrier delivers the call to us to transit for them to that LEC, would be blocked based on the above criteria).” 1 Further, Bell clearly states “Subscribers will not have information as to the number of blocked calls that were directed to their telephone numbers.” Given that Bell subscribers will not have any information on the number or nature of blocked calls, it is only logical to assume that third parties whose calls merely transit Bells network would also not be able to access information on the number and nature of blocked calls. We have no issue with Bell blocking calls to its own end-subscribers, but the idea that Bell will block […]