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February
2001
1. The PNO-ISC
(Public Network Operators - Interconnect Standards Committee) has
drafted a 3rd edition of the Code of Practice for
Network Operators In Relation to Customer Line Identification Display
Services and Other Related Services. The 2nd edition
was published in June 1998
2. The (i) current
and (ii) draft revised editions may be viewed by clicking on these
sites:
(i) Code
of Practice for Network Operators in Relation to Customer Line
Identification Display Services and Other Related Services (2nd
edition)
(ii) Draft Network
Operator CLI CoP (PNO-ISC/CP/169)
3. The Code
of Practice is produced by an industry body and endorsed by the
Director General. It is neither a technical standard nor a regulation
but represents a mutually agreed set of rules that network operators
have agreed to follow in order to establish a consistent framework
for the handling of CLI information across networks. One of its
objectives is to promote customer confidence in CLI display and
other related services by ensuring that the cardinal principles
of Privacy, Authenticity and Integrity are respected.
4. Modifications
to the Code of Practice may only be made by the Director General
after he has consulted with public network operators and any other
bodies or individuals that he considers appropriate. Accordingly
he is inviting interested parties to comment on the draft 3rd
edition. Comments should be sent to Frank Phillips, either at Oftel,
50 Ludgate Hill, London EC4M 7JJ or preferably by e-mail to frank.phillips@oftel.gov.uk by 6
April 2001.
5. The proposed
amendments to the CoP were extensively discussed at the 7th
CLI Interest Group (see paragraphs 3 - 20 of the draft
minutes.)
6. The Director
General would be particularly interested to receive comments from
the CLI community and other interested parties on the following
issues:
6.1 paragraph
6.12
The proposal
is that the Network Number should no longer be defined as the
number that defines the 'Network Termination Point (NTP)' but
rather as the number that defines the 'access' (either originating
or terminating) of a call. The generic term 'access' is proposed
as a substitute for 'NTP' throughout the document. The reasoning
behind this change is that within the family of Universal Personal
Telecommunications (UPT) services - where subscribers are able
to access network services from any line using a personal identifier
(PIN and/or password) - the user is no longer linked to a specific
NTP. However, the Network Number has traditionally been used
to identify the ingress port to or egress port from the public
network. Oftel does not think that is desirable to shift the
Network Number into the customer field, given that the number
identifying an individual subscriber can be used to populate
the Presentation Number field. Moreover, the demand for UPT
services in the UK appears to be very limited as consumers'
needs have largely been met by Personal Numbering services.
6.2 paragraph
7.2.4.2
The proposal
is to establish a new CLI classification where the CLI is 'withheld'
but classified as 'unavailable'. This is derived from an ETSI
specification and is intended for use by certain government
departments and other statutory bodies such as the police service
which may not wish to disclose their CLI but want to avoid the
rejection of their calls by an Anonymous Call Rejection service.
Oftel has serious concerns about this proposal, in the way that
it has been presented. It appears to take away consumers' privacy
rights conferred by European data protection legislation. Although
there is clearly a case for specified law enforcement activities
to be exempted from some aspects of data protection legislation,
the machinery already exists within the relevant Directives
for the Home Office and other relevant departments to establish
an appropriate legal framework. However in their normal day-to-day
business government departments and other statutory bodies should
be subject to the same data protection rules as everyone else.
Oftel will in any case be seeking the advice of the Data Protection
Commissioner as to the legality of this proposal.
6.3 paragraph
7.7.1
The proposal
is to extend the rules on incoming international calls to cover
the new case of the originating network having restricted the
CLI on behalf of the calling party where the CLI should be classified
as 'unavailable'. This proposal takes account of the possibility
that some overseas administrations may permit the use of the
new CLI classification described above. The existing rules that
the CLI should be classified as 'withheld' where there is an
explicit indication that the caller has invoked CLI Restriction
and that, otherwise, if CLI information is available it should
be classified as 'available' are essentially unchanged.
6.4 paragraph
7.7.2
The proposal
is for an entirely new section on outgoing international calls
which will require gateway exchanges to delete all CLI information
from a call where the CLI has been classified as 'withheld'
or 'unavailable' unless it is known that subsequent transit
and terminating networks will respect the caller's wishes by
acting according to the classification. By inference where the
CLI is classified as 'available' it will be available for display
by overseas networks.
7. Other significant
changes to the CoP which have already been publicised are:
7.1 paragraph
2.5
Redrafted,
on the advice of the Data Protection Commissioner, to define
more closely the uses that operators may make of withheld CLI
information
7.2 paragraph
7.2.2
This paragraph
reflects those changes to the Presentation Number service already
announced in the Oftel Statement on Type 3 Presentation Numbers
and previously the subject of a consultation.
8. Respondents
are also welcome to comment on those other aspects of the revised
CoP that have not been highlighted above.
Frank Phillips
CLI-IG Secretary
7 February
2001
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