India’s largest telecom company, Reliance Jio, noted that there were multiple “technical and data privacy” concerns with the caller ID proposal floated by the Telecom Regulatory Authority of India (TRAI). The company, in its submission, said that it would be prudent to not mandate the CNAP solution.
Airtel, on the other hand, acknowledged the proliferation of unsolicited commercial communications (UCC) and welcomed the proposal but called for it to be implemented in a “phased manner with industry consensus”. It suggested in its comments that the initial phase of the proposal should target telemarketing/ UCC calls specifically.
These submissions are part of the comments received by TRAI to its consultation paper on the introduction of Calling Name Presentation (CNAP) in telecommunication networks. It can prove to be quite handy as it looks to address the problem of UCC which remains a nuisance despite TRAI’S do-not-disturb (DND) registry.
You can read our summary of the paper here.
Why it matters: It is important to parse comments sent by telcos to TRAI because these companies are going to be the ones who will have to implement the measure. Moreover, it is critical to examine their submissions as the measure is likely to have a significant impact on them in terms of costs and call quality.
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Key takeaways from telecom companies’ submissions
Technical challenges highlighted by Jio: “The primary technical challenge is at device level. We have done a thorough analysis of the devices available in the Indian market and can summarize that there is no definitive record of feature phones being enabled with CNAP feature,” Jio said in its submission. It pointed out that smart feature phones working on 4G networks do not support this feature, whereas smartphones will require an update sent by most Original Equipment Manufacturers (OEMs). The possibility of the update causing issues at the operating system (OS) level cannot be discounted, according to Jio.
- Increased load on networks: The company wrote that there will be an increase in signalling load which will affect the time in setting up calls. There will be a consequent increase on network load and impact latency.
Importance of consent: “…there is a requirement of telecom consumer’s consent in sharing his name with a third party,” Jio noted in its submission. “There can be myriad reasons for the customers not being willing to share their name with the called party. A few of these can be potential fraud and risk of abuse, misbehaviour, social media stalking, etc.” read the submission, stressing that abuse increases for women.
Licence violations: “…mandatory provision of information to another customer (and through another third party TSPs, in case of inter-operator calls) can be deemed to be violative of Unified License Chapter-V-Operating Conditions on Confidentiality of Information,” the submission noted, while reproducing terms of the licence that direct a licensee to take steps to safeguard privacy & confidentiality of information about a third party and its business to whom it provides the service.
Allow room for existing mechanism: “…we submit that a mechanism to curb this (unregistered telemarketers) menace is already set up by the TRAI. We have deployed the latest technology and at a great cost to the service providers, and it should be allowed to function to address the problem,” the submission said. The company does not want to be saddled with the additional cost of setting up a CNAP facility to address a problem that can be handled by the Distribution Ledger Technology (DLT) based solution to address UCC.
May affect 5G: The company urged the TRAI to not contemplate any network-level changes such as CNAP because the Indian telecom sector was going through a phase of technology enhancement and all telcos were engaged in rolling out 5G services across the country. Jio reasoned that a change which can impact QoS, call set-up time, POIs and interconnected working of operators” can impact 5G roll-out consequently.
What are Airtel’s concerns: The submission also highlights similar issues as mentioned in Jio’s submission. It noted that only 65-70 per cent of the smartphones may be able to support CNAP functionalities, among other things.
Pricing based on market dynamics: “…we recommend that the option of charging the customer for CNAP should be left to market dynamics given the limited potential and uncertainty over customer opt-ins,” Airtel noted in its submission. It also urged TRAI to do a detailed cost-benefit analysis and Regulatory Impact Analysis (RIA) before deciding whether to adopt CNAP in India.
Need for a clear definition: “…the solution lies in creating a definition of UCC that is able to incorporate and identify unscrupulous callers who make use of the P2P route,” Airtel suggested in its submission, adding that such misusers of the service should be classified based on rational criteria. It proposed criteria such as analytics or predictive dialling patterns or calls/messages beyond certain thresholds/ volumes that may be defined as spam.
- “…a rule can be framed such that numbers of calls/messages from a P2P user beyond a specific threshold would be blocked by (telcos) and they would then necessarily come under the CNAP,” Airtel said.
Test first: Airtel said that a national level roll out should not be considered without a test first. It added that implementing “fresh changes on the entire base of one billion subscribers without any tests would be unsystematic and economically imprudent as it would force heavy costs/investments without any visibility into the effectiveness, while also impacting latency/call-set up issues for the consumer base”.
Balancing user privacy: Airtel called for privacy to be addressed in the framework but cautioned that a consent mechanism may leave CNAP ineffective as violators may choose to opt out of it thereby not revealing their name/identity in a P2P call.
Must stay within the telecom ecosystem: “We are also of the opinion that only a telco-owned, operated and neutral KYC’ed solution will benefit consumers and legitimate business entities, and generate the confidence and trust required to ensure that CNAP is effective,” Airtel said.
Leverage existing DLT investment: The company advised that the CNAP solution should leverage existing investments of telcos in DLT, and not add on any additional incremental cost without any practical justification.
Allow outgoing calls on national toll-free numbers: Airtel suggested that TRAI should consider permitting OG calls from 1800 numbers as it will allow the recipient to be aware of the origin of the call. The number has become the identity of enterprises due to business necessities and ease of customer access, as per Airtel.
What did other telcos like Vi and BSNL say?
Vi said that CNAP should be an optional service in India without any compulsion on telcos to launch it. It is no secret that the company’s submission has been shaped by the financial struggles staring at the company. Here are a few highlights from it:
Financial stress: The company said it was not possible for it to provide a separate expense for this service, and will have to come at the cost of rolling out 5G networks or expansion of 4G networks. It said that the government or the TRAI should bear the cost of CNAP if TRAI decides to implement it.
No clarity on 2G and 3G networks: “CNAP is generally a LTE feature and there are no standards for its implementation over 2G and 3G networks,” the submission said, adding that nodes of Vi’s legacy networks (which support 2G/3G) are on the “verge of end of service and end of life” and may not support CNAP deployment.
Is any model viable: The telecom watchdog had proposed four models for consideration in its consultation. Vi believes that all the four models would result in “increasing switching time/processor load, latency, delay in call setup time and huge costs” for telcos. The company advised that the TRAI should carry out a Regulatory Impact Assessment before it recommends a model.
- Alternative model: The company recommended an alternate way of providing caller name information to consumers through a Common Mobile App (CMA) which can be built by a trusted party like C-DOT. It added that the app will integrate subscriber name databases from all telcos in a secured way.
- “Only the consumer who downloads the app will be able to see the name of the caller, as provided in the KYC database. Privacy features can be integrated in this app which will disallow storing/saving/sharing of this information with any other 3rd party app or OS provider,” the company said.
The government-run company was also of the opinion that CNAP should not be made mandatory at this stage. “For making the mandatory activation for each subscriber there may be challenges with legacy network elements which may not be capable of providing this facility to all of its customers,” the company said. It must be noted that BSNL is likely to have many of these existing legacy mobile telecom networks which will not support CNAP.
“There is (a) challenge in developing CNAP functionality in these legacy network elements. These network elements will need to be replaced with new technology elements, which may take quite some time,” BSNL wrote in its comments.
Do not limit CNAP to CAF: The company said that the option of acquiring details for the database should not be limited to the Customer Acquisition Form (CAF) database. “Subscribers may be allowed to use their preferred name, commercial name, a public institution or non-governmental organisation’s name, trademark etc. for display,” the company suggested after submitting relevant documents.
Many of the recommendations covered in this report were also suggested by the Cellular Operators Association of India. The body, which comprises telcos like Airtel, Jio, and Vi, was not too enthusiastic about the proposal as it stated that the CNAP service would only render duplication of a feature/service that is already in use (apps like Truecaller), and cause a dilemma to the party receiving the call. You can read their submission here.
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