Apologies (item 1)

1. Apologies and those present are listed in the Annex to these minutes.

Minutes of sixth meeting (item 2)

2. The minutes of the 6^th meeting (doc 00/004 minutes) were accepted without amendment.

Draft 3^rd Edition Network Operator CLI CoP (PNO-ISC/CP169 Issue 2) (item 3)

Draft Network Operator CLI CoP (PNO-ISC/CP/169)

3. Peter Clarke introduced the draft 3^rd edition and highlighted the most significant changes. These were:

• recognition of the new 4^th APRI value that had been assigned
• changes in the handling of international calls
• the replacement of the term "NTP" by "access"
• the introduction of the Oftel amendments

(Suggested amendments to Code of Practice for Network Operators in Relation to Customer Line Identification Display Services and Other Related Services (2nd edition) CLI-IG CP (00) 002)

Subsequent discussion concentrated on the following paragraphs of the draft CoP.

4. (7.2.2) Conditions to be met by a presentation number Richard Cox argued that the section preventing PRS numbers being used as Presentation Numbers should be strengthened by the addition of the words or as designated by the DG to the proposed text: those numbers that are either prefixed 090 or 091 or will migrate to those prefixes.

5, Ian Spiers said that this would require a lot of data changes.

6. Peter Walker said that the DG had no legal power to make a designation in this context as the CoP was not a statutory instrument. He though the words will migrate captured the situation where PRS numbers were temporarily hiding behind a misleading prefix.

7. Michael Dixon said that 090 and 091 sent a warning to callers as also did 070 (the personal numbering range).

8. Alan Presland pointed out that the 3^rd bullet of paragraph 7.2.2 was not very clear. He agreed to propose a revised text, as follows:

where the [number to be used as a] presentation number has not been directly allocated to a party or its affiliated companies, that party must have written consent from the allocated owner for its use as a presentation number and confirmation that

this consent has not been withdrawn (wording in square brackets introduced by FP)

This text has been submitted to the PNO-ISC.

9. (7.2.4.2) Exceptional circumstances for network number 'unavailable' without a Presentation number This is an entirely new CLI classification intended for use by government departments and other statutory bodies which wish to withhold their number but avoid rejection by an Anonymous Call Rejection (ACR) service. Instead of 'withheld' the CLI on these exceptional calls would be classified as 'unavailable'.

10. Frank Phillips expressed misgivings about this new classification and recalled that at the UK's insistence a similar provision had been excluded from the ETP Guidelines.

11. Peter Walker explained that the proposed classification would breach data protection legislation and that one way organisations could maintain their anonymity when it was imperative to make a connection was to route their call via the operator.

12. There was an extensive discussion about this proposal. It was agreed that the Data Protection Commissioner's opinion needed to be sought, and recognising that France was probably the initiator of this proposal there might be some value in bilateral discussions with ART, the French regulatory authority.

13. (7.6) Networks covered by, but which do not conform to, this CoP This is an entirely new section on calls received from non-CoP compliant networks where Rule CLI-16 will be invoked. As a result the CLI classification will be set to 'unavailable' in circumstances where either (i) the integrity of the classification cannot be maintained or (ii) the call has been classified as 'available' and the integrity of the CLI information cannot be maintained but the classification can.

14. The relevance of this to VoIP services was discussed, Peter Walker pointing out that VoIP operators did not qualify for Annex II and therefore had the same standing as end-users. Richard Cox expressed misgivings that breaking a call in and out of VoIP would create an 'unavailable' classification.

15. (6.12 and elsewhere) Network Number Throughout the revised CoP the term network termination point is replaced by access, itself undefined. In paragraph 6.12 a Network Number is now defined as:

the digits that comprise a unique E.164 number that the public network unambiguously identifies as the originating or terminating access of a call.

The previous definition was:

the digits that comprise a unique E.164 number that unambiguously identifies the ingress port to, or egress port from, the public network, ie the network termination point (NTP).

16. Peter Clarke explained that whereas 'NTP' was fine for fixed-line services the term is less applicable within a UPTs (Universal Personal Telecommunications) context where the user is not linked to a specific NTP. The key identifier will be the access, used for identifying or charging. As an example, where a doctor calls from a patient's line the numbers involved could be:

• the patient's NTP number
• the doctor's UPT number
• the doctor's group practice Presentation Number.

17. Alan Presland said that UPT needs thinking through; the Network Number would still be needed to identify the access for Malicious Call ID purposes.

18. Peter Walker commented that there was no UPT service in the UK and thought that the term 'access' was ambiguous, having too many meanings within a European context. He asked the operators present what their view was but there was no immediate response.

19. Frank Phillips pointed out that under paragraph 3.3 of the existing CoP modifications required consultation with public network operators and other appropriate bodies. The CLI community reflected in the Interest Group had been considered sufficiently representative for the consultation leading to the adoption of the 2^nd edition of the CoP.

20. A consultation on the draft CoP would be launched through the Interest Group's website, using the currently posted version but with an Oftel-supplied preamble.

AP 7/1: members to comment on the draft CoP which will be the subject of a consultation within the CLI community (see CLI-IG webpages)

Service Provider CLI Code of Practice - status report (item 4)

CLI-IG CP (00) 010 Service Provider Code of Practice -extract of Roland Perry email to Oftel dtd 02/01/01

21. Frank Phillips introduced the report on the progress of the Service Provider CoP, supplied by Roland Perry of LINX.

22. Peter Walker disagreed with the proposed conformity between "public network" and "publicly available telecommunication services (PATS)" adding that the CoP was intended to provide a basis for interconnection between Annex II and non-Annex II operators and that the difference between the two should not be elided. A number of regulatory consequences arose from a non-Annex II operator being behind the NTP.

23. There was consensus that what had been produced so far was not sufficiently stable to be forwarded to SPIG and Richard Cox, speaking, for LINX, proposed to convene a meeting of interested Service Providers to carry the work forward.

AP 7/2: LINX to convene a meeting of service providers

Cross-border CLI (item 5)

24. (a) reception of the ETP Guidelines

ETP Guidelines for Calling Line Identification - Issue 2

Frank Phillips explained that Oftel had circulated the ECTRA Recommendation on the ETP Guidelines ( CEPT/ECTRA Recommendation of 22 June 2000 on the implementationand use of CLI (Calling Line Identification) within CEPT countries (ECTRA/REC(00)03) to NRAs through the Independent Regulators Group (IRG) with a view to gaining support for the following statement:

ETP invites members of IRG to confirm that they note the ECTRA Recommendation of 22 June 2000 [ECTRA/REC(00)03 - E] and will encourage national operators to adopt the Recommendation.

This proposal is currently undergoing the first stage of the IRG's three-stage electronic clearing process.

25. (b) ISC letter on International CLI PNO-ISC/L119

PNO-ISC's proposal is that outgoing CLI should only be deleted where the CLI has been classified as "withheld" or "unavailable". This is now reflected in paragraph 7.7.2 of the draft 3^rd edition of the Network Operator CoP which is currently being consulted on.

26. (c) CLI-IG CP (00) 011 - Extract from ODPC letter to Oftel

The Data Protection Commissioner's written advice on the export of CLI information - a response to the PNO-ISC letter - was considered.

27. Although it unequivocally stated that there was no problem with the export of CLI information to European Economic Area (EEA) countries - with regard to non-EEA countries, the advice although positive, was hedged with qualifications. Frank Phillips was requested to seek a more explicit declaration.

AP 7/3: Secretary to seek clarification of ODPC’s opinion on export of CLI information

Secretary’s note: Discussed with Philip Jones and Lorraine Godkin of the ODPC on 18/01/01. Their view was that it is permissible to export CLI information to non-EEA countries provided that the Data Controller (ie the operator) has a reasonable degree of confidence that (a) the data will not be misused by the terminating operator, eg to make marketing calls to the captured numbers and (b) that network security in the receiving country is of a sufficient level to prevent data being captured by third parties, ie hackers.

Unintended release of CLI on diverted calls (item 6)

CLI-IG CP (00) 008 Extract from BT letter to Oftel

28. The letter explained that there are exceptional circumstances in which a withheld CLI may inadvertently be displayed when a call is diverted to another network and the called customer has inserted the unblocking code 1470 between the divert code and the destination number.

29. The problem can be fixed, in the interim, by making a data change in the relevant switch pending the switch supplier's provision of a permanent fix.

30. Ian Spiers agreed to circulate the information within the ISC group.

AP 7/4: Ian Spiers to circulate within ISC group

Concatenation of dialling prefixes (item 7)

ISC letter on Concatenation of Dialling Prefixes PNO-ISC/L118

31. The advice from the ISC - that the blocking code (141) should always be entered before any indirect access code - was noted.

Partial CLIs (item 8)

CLI-IG CP (00) 009 Partial CLIs - Extract from BT letter to Oftel 20/10/00

32. OLO switches forward a Partial CLI or PCLI (in response to the request for a CLI at the terminating end) in circumstances where a full CLI cannot be supplied. This could be for a number of reasons - an analogue system, an international call, a outgoing-only line. The PCLI includes fields identifying the operator and the particular switch.

33. BT currently allocates PCLIs on behalf of the NICC and PNO-IG - although this function will pass to Oftel's Numbering Unit - but has no enforcement role where OLOs have not applied for them. There have been a number of recent instances when the request for a CLI has been met by a blank field or meaningless digit strings rather than a proper PCLI. BT would like some form of pressure to be exerted on OLOs so that they use PCLIs.

34. Peter Walker recognised the value of PCLIs for emergency routing and call tracing. He thought the problem was more acute among small operators incapable of transiting CLI. A two-pronged approach was for a PCLI allocation to form part of interconnect contracts and for Oftel to encourage operators to take it up. However the DG had no statutory powers to impose PCLIs on recalcitrant operators.

35. Dee Cheek said she would look at the contractual position.

36. From here the discussion broadened out into the general issue of rogue or unavailable CLIs. Alan Presland said that BT was increasingly receiving the wrong kind of information from some interconnecting operators.

37. Eden Guiseley said that NTL's experience was that autodiallers were the key offenders. There had been a steady increase in rogue CLIs over the last quarter. A call centre in Newcastle working for a certain electricity power generator was sending up to 15 silent calls a day to some customers. Rogue CLIs were being used to by-pass ACR and at least two police forces in the East Midlands were allegedly converting their withheld CLIs to unavailable. He asked what an operator could do when customers 'tweak' their CLIs. Peter Walker pointed that a specific licence condition in the SPL/TSL (TSL condition on Calling Line Identification) forbids the sending of misleading CLIs.

38. Peter Walker said that the question of CLI unavailability was best tackled, not as a customer protection issue where regulation might be disproportionate, but as a matter for the Home Office as a law enforcement issue.

39. In response to Dee Cheek's view that all operators should provide either full or partial CLIs, Simon Sporton said that Vodafone did not provide PCLIs but preferred to use a full default CLI (where the number given in response to a request for a CLI is that of the operator's help desk).

40. Richard Cox said that one way of squeezing out rogue CLIs was for operators to be required to log CLI information on call data records. Peter Walker thought this would be disproportionate.

AP 7/5: Oftel to write to interconnecting operators encouraging take up of Partial CLIs

Procedures for Type 3 Presentation Numbers (item 9)

CLI-IG CP (00) 006 - Applications for type 3 PNs

41. It was recorded that through helpful collaboration with the industry, procedures for managing applications for Type 3 Presentation Numbers had been agreed. Frank Phillips noted that Oftel had not yet had to consider any such applications.

User information (item 10)

42. (a) revised Consumer Guide to CLI Services

Consumer Guide to CLI Services

The revised version has been open to comment since the previous meeting. All such comments received have been incorporated so it is now ready to replace the original, 1998, version.

43. (b) results of Oftel customer survey

http://www.Oftel.gov.uk/research/2001/fix0101.htm

The November 2000 Oftel SME Survey included a section on CLI services. The full report is posted at the above address but, apart from the general level of satisfaction expressed (95%) a number of findings were noteworthy. The high level of awareness of Call Return (95%) and the ability to withhold CLI (93%) contrast with the low level (30%) awareness of ACR services. This suggests that the operators are failing to meet their obligations under the TDPD Regulations (The Telecommunications (Data Protection and Privacy) Regulations 1999 (07/99)) to take reasonable steps to publicise the CLI facilities available. The Consumer Guide could be of assistance in this respect.

Submission to CLI Interest Group - for discussion (item 11)

CLI-IG CP (00) 007 Submission to CLI Interest Group

44. Mike Norman delivered his paper on through-routing of CLI on calls received on a private network before being routed back on to the public network. At present such through-routing would be prevented by the approach Oftel has taken to Type 3 Presentation Numbers, where the PN used must either have been allocated to the caller or there must be a written agreement for its use.

45. Peter Walker responded that some off-network problems such as those surrounding NTS operators would be solved by the Service Provider CoP. One case for supporting the Siemens proposal was the 'chain of trust'. If the CLI originally received by the private network was authentic and trusted why shouldn't it be passed on.

46. Richard Cox opposed this proposal on the grounds that it could be exploited by an unscrupulous user.

47. Alan Presland thought that if through-routing was allowed it might put pressure on smaller operators to weaken the current Type 3 PN rules.

48. Mike Norman said that some departments within a company might wish to send an 0800 number. In support, Peter Walker cited the example of the DSS which exploited Presentation Numbers to present different number types according to the needs of the various parts of the organisation – including DDI, switchboard and low tariff numbers. He also thought it would be permissible to think about changing the existing Type 3 rules.

AP 7/6: members to respond to Mike Norman’s proposal

Any other business (item 12)

49. Frank Phillips asked for an informal progress report of how work was progressing on the ACR specification for ISDN and GSM in ETSI and the ITU. It appears that the specification for ACR on ISDN is well advanced. However, on GSM the picture looks rather less promising as the major push on standardisation work is now being directed towards 3GPP where ACR is not viewed as a priority item.

50. Finally, Frank Phillips also canvassed the views of Oftel’s stakeholders within the CLI community on the objectives of the CLI Project (#C14), as described in the draft Management Plan 2001-2 posted at www.Oftel.gov.uk/about/drmp1200.htm

Secretary’s note: please send any amendments to these minutes to frank.phillips@Oftel.gov.uk by 7 March

ANNEX

Present:

BBC Chris Bell
BT Regulatory Affairs Dee Cheek
BT Alan Presland
BT Dave Lane
Cable & Wireless Peter Clarke
CCTA Alan Bennett
CMA/Foskett Powell Michael Dixon
Energis Thomas Schmidt
LINX Shelagh Shaw
Mandarin/LINX Richard Cox
Marconi Communications Ian Spiers
ntl: Eden Guiseley
Orange William McCoubrey
Siemens Communications Ltd Mike Norman
Telia Alan Penny
Viatel Lee Fairweather
Vodafone Simon Sporton
Oftel Peter Walker (Chair)
Frank Phillips (Secretary)
Phil Cobb
Neil Nasralla

Apologies

CMA/Bass plc John Pook
Data Protection Commissioner Lorraine Godkin}
Kingston Halim Inceer
LINX Roland Perry
Telewest Sara Jane Amey
Torch Justin Slorach

Secretary’s note: as the CLI-IG minutes are posted on an open-access website participants' e-mail addresses are no longer listed, although available on request from me.