The Government has today announced changes that enable them to “crack down” on nuisance callers. We really welcome this and as regular readers will know, we’ve commented before on changes overseas and unique Simwood features to help protect from the misery unwanted calls cause. However, we have also made suggestions to the Department of Culture Media and Sport to make the process of Nuisance Call Handling fit for purpose. Whilst we welcome the changes announced today they fail to acknowledge the points we made, and exacerbate the factors behind them.
The announcement also suggests the Government is looking to enforce mandatory Caller ID (CLI) for marketing callers. Whilst welcome, it is common practice for marketing callers to already present CLI because it improves answer rates and bypasses basic Anonymous Caller Reject services. The problem comes in that the CLI they use isn’t necessarily their own! Enforcing them to use one risks more calls bypassing Anonymous Caller Reject services, and more complaints into a broken complaints process. Furthermore, whether CLI is withheld from the callee or not, a call compliant with existing OFCOM requirements will have a valid CLI visible to operators at a lower level anyway.
When a consumer calls their phone company, and lets take BT as a significant example, the handler will lookup the number given on their system and tell the caller who the Range Holder is. In our experience, where some of our unallocated numbers have been falsified by overseas call centres, this has resulted in the caller being told “Simwood has called you”. Aside from the anti-competitive nature of this, this leads to substantial confusion and actually a third victim as the wrath of the harassed consumer is mis-directed.
In our case we have been forced to place a notice to consumers right on our home page explaining this. Thankfully many years after this problem started it is now at least acknowledged as existing but the process hasn’t changed. This therefore means today’s changes allow a bigger fine for someone that still cannot be identified, and talk of forcing more of the behaviour that caused the problem in the first place!
We again ask OFCOM and the DCMS to reform the Nuisance Call process within the incumbent and other major operators to avoid this harm. They simply need to look more deeply into where the problem call actually entered their network, rather than which operator’s number was used. That is something we do routinely; it is not hard. The old process was appropriate 40 years ago; it is not today where an operator or even retail customer could use different networks for inbound and outbound calls, thus needing to present some other network’s CLI on outbound calls and therefore having the ability to abuse it.
The irony of the situation is that certain large incumbent operators have major Global Services operations, offering IP voice termination services into global markets. It would be fascinating to know how many nuisance call reports from their own consumer customers actually resulted from their own Global Services customers, and further how many involved falsified CLI. We of course do not have those figures to make any such accusations.
The further irony is that the Narrowband Review, whilst benefitting the incumbent, also dramatically lowered the cost of placing Nuisance Calls! We warned of this at the time and sadly note the experience of our US contemporaries where a number have felt they had no choice but to sell out of legitimate business and now make most of their income from carrying junk calls. We will shut up shop before that but the regulatory pressures on all but the incumbent are encouraging that.
For customers of Simwood, it is widely known that we have a zero tolerance for Nuisance Calling and actively jettison traffic from the network that fits that profile. In addition to Intelligent Caller Reject to help our customer’s end users, we also expect the use of valid and well formed CLI. Customers will receive warning messages in SIP responses where invalid CLI is passed. There is an account level setting which will require valid CLI on every call which we enable where necessary. For responsible customers there is also the option to lock the CLI presented on a given trunk, thus causing us to ignore what is passed through and preventing end-user abuse. We strongly encourage their use.