In its latest move to combat illegal robocalls, the Canadian Radio-Television and Telecommunications Commission (“CRTC” or “Commission”) has just released a Notice of Consultation (“NOC”), inviting public comments on its proposal to require all telecommunications service providers (“TSPs”) offering voice telecommunications services in Canada to participate in its call traceback process. Participation in the traceback process in Canada is currently optional, and the CRTC is concerned that not enough voice service providers are participating voluntarily. Initial comments (interventions) on the issues raised in the NOC are due March 29, 2024, while the deadline to file reply comments is April 12, 2024.
Background
In 2018, the Commission determined that in addition to other anti-robocall measures, a standardized, industry-wide call traceback process was needed in order to identify the origin of nuisance calls. Without such a process, it was impossible to determine where calls made using spoofed telephone numbers actually originated. Following a successful trial of the process, the CRTC approved the permanent rollout of the traceback process in August 2021, moving it towards full deployment. However, the Commission did not make service provider participation in the process mandatory.
As of February 28, 2024, only thirteen voice service providers participate in Canada’s call traceback process. The CRTC recognizes that this small level of voluntary participation, though successful, is insufficient to realize the full potential of the traceback process. Accordingly, the NOC seekds to make participation in the traceback process by all providers of voice telecommunications service in Canada obligatory.
Call for Comments
The NOC invites comments from all registered TSPs on the following specific issues related to the mandatory implementation of the call traceback process in Canada:
- The appropriateness and effectiveness of imposing a requirement on all TSPs, as a condition of offering and providing telecommunications services pursuant to sections 24 and 24.1 of the Telecommunications Act, to respond to traceback requests in compliance with the process approved by the Commission from time to time. Submissions regarding anticipated costs, operational burdens, or technical challenges should be supported with specific evidence.
- The appropriateness of including certain specific elements in the traceback process.
- Would any other modifications to the process approved by the Commission in CRTC Compliance and Enforcement and Telecom Decision 2021-268 and NTWG contribution NTC0707 be appropriate?
- Would it be appropriate and useful for the CRTC to publish individual trackback results specifically to identify (i) the associated call campaign of a specific traceback demand, (ii) the date and time of the call, and (iii) the originating Canadian carrier for domestic calls or, for international calls, the first Canadian carrier and the last foreign carrier in the call path? Additionally, how often should such results be published?
The CommLaw Group Can Help!
Since all voice service providers operating in the U.S. should already be participating in the call traceback process, expanding participation to Canada should not be burdensome for these providers. If your company has questions about the NOC, is concerned about its readiness to participate in the traceback process, would like assistance with filing comments or reply comments on the NOC, or has other Canadian robocall compliance questions or concerns, please contact Michal Nowicki at mjn@commlawgroup.com, Michael Donahue at mpd@commlawgroup.com, or Ron Quirk at req@commlawgroup.com.
