Ofcom have recently published Draft CLI Guidelines which will likely become part of the General Conditions in 2018.
Notably, these proposals will require much stricter checks of CLI in an effort to protect consumers from the misuse of CLI that has become increasingly prevalent since the widespread adoption of VoIP technology, and control of CLI largely passing into the hands of the caller (or small companies)
Our AUP has always covered CLI, and requires that all customers prevent valid CLI on all calls. We’ve also long tried to encourage appropriate and valid use of CLI, and actually block invalid CLI already.
There is a certain irony though, given the new Nuisance Call Regulations which precede this required a CLI be presented, regardless of whether it was appropriate, and arguably removed the ability to ignore/filter calls with ‘witheld’ CLI. Another stable door we pointed out was open nearly closed then…
CLI Services to be standard
Communications providers must provide CLI facilities and enable them by default. Communications providers will no longer be able to charge for caller ID services unless it is demonstrated to be not technically feasible or economically viable to do so, which is unlikely. We never quite understood the moral justification to charge for turning something off!
Simwood has never levied an additional charge for CLI services, and are pleased that this valuable information will be available to everyone without charge on their PSTN lines too.
Invalid CLI must be rejected
Where technically feasible, the CP must take all reasonable steps to identify calls which have invalid or non-dialable CLI data and prevent those calls from being connected to the third party.
This obligation applies to every CP in the chain; i.e. you must not accept calls from invalid CLI, we must not route them and, if calls do reach you with invalid CLI, you must not connect them to your customer.
We already have everything in place to offer this as part of our Intelligent Call Rejection functionality. We welcome the introduction of regulation in this area and will be able to meet these requirements easily.
Originating CPs must ensure CLI is correct
CLI must only be presented from a number range allocated to you, or that you have permission to use. Where calls originate internationally, at the first point of ingress any CLI that cannot be reasonably trusted (or is unavailable) will be replaced with a CLI from a new dedicated range for the purpose to facilitate effective call tracing.
There will always be some exceptions for “Presentation Numbers”, notably where a call traverses your network but is then forwarded where you can legitimately present the number that called, as this identifies the caller. We will ensure this ability is preserved, but there may be some minor changes required to how you pass these calls to us.
Where we can help
Simwood has always taken a stance against misuse of our network, and the vast majority of our customers are generating traffic that will not be affected by these regulations from the outbound side.
Those few who are still occasionally sending incorrect CLI, please see this as your final remainder, we have always reserved the right to drop such calls and soon this will likely become a legal requirement.
We’re also pleased to help our customers meet their obligations under GC6, and intend to introduce a range of tools allowing customers to customize how we handle invalid CLI to their numbering.
Due to the unique nature of our platform, where we already perform over 200 checks per call set-up to help keep you safe from fraud, implementing strict checks on valid CLI will be trivial, enabling you to comply with the revised GC6 from day one. No doubt ‘me too’ will need to start the provisioning process for a new magic box!
Your CLI and the Emergency Services
The Ofcom consultation also places a heavy focus on the importance of CLI for the emergency services and location information being derived from this.
Whilst this made sense in a fixed-line POTS world, it’s our view that (although outwith the scope of this consultation) the use of the Network Number alone to provide location information to the emergency services is outdated, primitive and has failed to evolve with modern technology such as VoIP-based services.
Many VoIP users are truly nomadic, and our customers often raise concerns about submitting address data for this purpose. With IP-based connectivity it seems reasonable that location information could be provided within the signalling (either in address format, or data from embedded GPS within the calling party device)
We would love to see a situation where, instead of submitting address data for 999, calls could simply be sent with additional headers in the INVITE e.g.
P-Emergency-Location: premises=Simwood House;postcode=BS16 1FX P-Emergency-Location: lat=51.523918;long=-2.528834 P-Emergency-Location: ref=ST6341880688
Whilst it’s unlikely that this would appear as a standard any time soon, we feel that relying on traditional CLI for this purpose in an IP world is inappropriate, and has the potential to put people at very real risk.
Until a more forward-thinking option is adopted, we would remind all customers that it’s imperative they submit address data for any CLI that may call 999 and that the official policy of the EHA is they would rather have some address information on file (even if the user is nomadic) than none at all. The emergency call handler will always confirm the address with a caller who can speak, but any address is better than no address where they can’t.