Provision of Directory Information Services and Products
September 1997
Foreword
Directory services and products, from basic directory
enquiry services and phone books to enhanced services on the Internet,
are important to customers. They benefit the industry too as they stimulate
use of telecommunications networks.
While competition has radically changed the rest
of the telecommunications market, provision of directory services has remained
much as it was before BT was privatised. Most consumers still rely on BT's
directory services and products.
The proposals in this document for the provision
of directory services and products aim to balance the privacy concerns
of customers with a framework for competition that will give customers
more choice and encourage innovation and efficiency. We have worked closely
with the Data Protection Registrar to get this balance right.
These proposals aim to :
I want genuine and open consultation and would like
your views before taking any decisions on the best way forward.
DON CRUICKSHANK
CONTENTS
CONSULTATION
The initial consultation period will run until 31 December
1997. There will then be a further period up to Friday 16 January 1998
during which comments are invited on any submissions made to Oftel. Comments are
invited in particular on the questions at the end of the various chapters which
have been summarised in summary
of questions.
Written comments should be sent to:
Andrea Konrath
Oftel
50 Ludgate Hill
London
EC4M 7JJ
Fax: 0171 634 8893
Written comments will be made publicly available
in Oftel's Library unless confidential. Respondents are therefore asked
to separate out any confidential material into a clearly marked annex.
Appointments to view written comments in the Library must be made in advance
(tel: 0171 634 8762/8765, fax: 0171 634 8946).
Comments can also be sent to Oftel on the Internet
via Oftel's Web pages or by using the following e-mail address:
crs.oftel@gtnet.gov.uk - marked for the attention
of Andrea Konrath
Oftel intends to set up a link between this document
on Oftel's Web pages and any comments about it placed on respondents' own
Internet pages. Please contact Cate McLaurin at Oftel on 0171 634 8752
to organise this. Or e-mail press.office.oftel@gtnet.gov.uk
WORKSHOP
A public workshop to discuss this document will take
place on 10 November in London. Please contact Elizabeth Watts at Oftel
(tel: 0171 634 8770) to register and receive details of the location and
timing.
A short booklet summarising the key issues for customers
is available. Copies can be obtained from Elizabeth Watts at Oftel (tel:
0171 634 8770).
COPIES ON DISK
Visually impaired customers who wish to have access
to the text on computer disk should contact Elizabeth Watts at Oftel (tel:
0171 634 8770).
Oftel Research
Summary
1 This document is about the provision of directory
information services and products. It sets out Oftel's proposals to achieve
the following objectives:-
2 The telecommunications industry derives a direct
benefit from the use of directory information services and products in
that they generate revenue from follow-on calls as a result of successful
directory searches.
Protection of Privacy
3 It is important that directory information is not
used in ways which raise privacy concerns for customers. A draft Code of
Practice has been drawn up by Oftel in consultation with the Data Protection
Registrar which sets out permitted uses of directory information based
on customers' expectations of how their directory information will be used.
A draft Code of Practice on uses of directory information
is included at Annex
C for comment. Oftel proposes that the licences of all operators responsible
for collecting directory information (PTOs and other licensees entitled to number
allocations) are modified to require that they abide by the Code of Practice
and that they require any third parties to whom they supply directory information
to comply with the Code through contractual arrangements.
Both Oftel and the Data Protection Registrar will have a role in enforcing
the Code of Practice.
4 The names and addresses of ex-directory customers
currently appear in the databases used by directory enquiry (DQ) services,
so that the DQ operator can confirm to an enquirer that the number is ex-directory.
Oftel has outlined two options for consultation
on whether or not ex-directory customers' information should be made available
to providers of DQ services.
5 Proposed European legislation gives customers
the right to indicate that their directory information may not be used
for direct marketing. Oftel research indicates that around half ex-directory
customers had chosen ex-directory status to avoid nuisance calls, which
may include telesales calls, and almost a fifth specifically mentioned
avoiding telesales calls as a reason for being ex-directory. Therefore,
a directory status option which enabled customers to opt out of their directory
information being used for direct marketing would meet the requirements
of proposed EU legislation and might reduce ex-directory levels.
6 The Telephone Preference Service (TPS) already
offers a means by which customers can opt to reduce unwanted telemarketing
calls. However, Oftel research indicates that only 10% of residential customers
were aware of the TPS.
In order to meet the requirements of proposed
EU legislation Oftel proposes that customers should be able
to opt out of their directory information being used for direct marketing
(both telemarketing and direct mail); that all directory entries should
carry a flag to indicate whether the customer has opted out; and that the
Code of Practice on uses of directory information should prohibit use of
such entries for direct marketing. If these entries were subsequently used
for direct marketing this would be in breach of the Code of Practice and
the Data Protection Act.
More Comprehensive Directories
7 There are two aspects to improving the comprehensiveness
of directory information services: stopping the growth in the proportion
of customers opting to go ex-directory and if possible reducing ex-directory
levels; and ensuring more types of numbers are included in directories.
Reducing demand for ex-directory status
8 The proportion of residential ex-directory customers
has risen from 24% in 1991 to 37% in 1997. Oftel's research indicates that
if ex-directory residential customers were given more choice about how
their directory information is used, some would be willing to have a directory
listing. Proposed European legislation will also require customers to be
offered certain choices about their directory entry and how it is used.
Oftel proposes that all customers be offered
a wider choice of directory status options which are agreed across the
industry and included in the Code of Practice. Based on the requirements
of proposed European legislation and market research Oftel has recommended
a range of possible options (see Chapter 5 paragraph
5.8 for details of Oftel's proposals) for consultation.
Expanding the range of numbers in directory services
and products
9 Currently, the coverage of numbers such as mobile,
fax, and pager numbers in directory information services is very limited.
For example, only around 0.6% of mobile numbers are available from most
DQ services. There is customer demand for more types of numbers to be included.
Current licence obligations require PTOs to supply their customers with
a directory information service covering numbers used for voice telephony
services. The inclusion of other types of numbers such as fax and pager
numbers is not covered by current licence obligations.
10 Proposed European legislation will require
the provision of DQ services covering all telecommunications numbers used
for publicly available telecommunications services (not just voice telephony),
and that printed or electronic directories containing these numbers are
made available.
In order to ensure that directory information
on all telecommunications customers is made available to providers of directory
services and products, Oftel proposes to modify the licences of all companies
which have an entitlement to receive direct allocations of numbers. The
modification will require the licensee to collect directory information
from customers to whom they supply publicly available telecommunications
services (not just voice telephony services) and supply it on request to
those wishing to provide directory services and products. Where the licensee
sub-allocates numbers to service providers who in turn assign those numbers
to customers, the licensee will be responsible for collecting directory
information from the service providers and ensuring that it is supplied
on request to providers of directory information services and products.
Future changes to the entitlement to receive direct allocations of numbers
(eg direct allocations to service providers and use of the 05 range for
corporate users) will need to take account of the requirement to collect
and supply directory information.
Oftel proposes modifying all PTO licences
to require PTOs to provide their customers with access to a directory information
service covering all customers of publicly available telecommunications
services issued with numbers from the National Numbering Scheme.
Expanding the Choice of Directory Services and Products
11 There is a number of factors preventing independent
service providers and PTOs from developing new and varied directory services
and products for customers. This document identifies the major obstacles
to competition and outlines a detailed set of proposals to enable more
competition to emerge.
12 Oftel's proposals are as follows:
Access to directory information
Modify the licences of all licensees who are
entitled to receive direct allocation of numbers to include an obligation
to supply directory information (the Code of Practice will specify what
information should be provided) - both as on-line access and downloads
- to PTOs and independent service providers at published reasonable charges.
Standard data format specifications to be drawn up by the industry.
Charges for directory information to be
decided by commercial negotiation, with Oftel having power to intervene
to resolve disputes and deal with any anti-competitive behaviour.
Access to directory information on core databases
(ie databases containing aggregated directory information from a number
of licensees)
Licence modifications to require BT to provide
downloads of the directory information
(on its customers and the customers of other operators) contained
in its core database to other PTOs and independent service providers on
request until the market for core databases is competitive. Charges for
downloads to be reasonable and a price list to be published. Per look-up
(or similar) charges to be offered.
Downloads to be provided from BT's Retail
Systems Business to BT's directory businesses, other PTOs and independent
service providers on the same terms.
BT to pay other licensees to hold their
directory information on its core database, not to charge them.
Access to product databases for directory enquiry
services
Licence modifications to require BT to provide
other PTOs and independent service providers with on-line access to the
directory information database it uses to provide its directory enquiry
service until the market for directory enquiry databases is competitive.
Charges to be reasonable and a price list to be published. Per look-up
(or similar) charges to be offered.
BT's directory enquiry database to be moved
from its Systems Business to its Supplemental Services Business so that
it purchases inputs (downloads from BT's core database from BT's Retail
Systems Business) on the same terms as independent service providers and
other PTOs who may develop competing databases.
DQ services
Move BT's DQ service to its Supplemental Services
Business so that BT purchases inputs on the same terms as independent service
providers.
Because there are not enough three digit
access codes for competing DQ services, require all operators to migrate
their inland and international DQ services to new five digit access codes
following a suitable period of parallel running. If three digit codes (192)
continued to be used for existing DQ services, new competitors would be
disadvantaged by having to use five digit codes. And if existing DQ services
continued to use 192, customer familiarity would favour these services
and competing services would be disadvantaged.
Two numbering options are considered, 118XX
or 192XX. Use of 192XX presents considerable technical difficulties and
will delay the use of access codes by competing DQ providers. Europe has
recommended the use of 118XX for DQ services and the use of this code does
not create such technical difficulties. Oftel proposes that, subject to
consultation, 118XX is used for DQ services.
Require operators with market power in the
supply of basic telephony (currently BT and Kingston) to allow their customers
to have access to any DQ service provider by dialling a five digit access
code.
Require operators with market power in the
supply of basic telephony (currently BT and Kingston) to bill their customers
on behalf of other providers of DQ services if the ordinary telephone bill
is used for their own DQ service.
Phone books
Require operators with market power in the
supply of basic telephony (currently BT and Kingston) to unbundle the price
of phone books from line rental by raising a separate charge on the bill
so that customers have a choice as to whether to buy a phone book.
Require operators with market power in the
supply of basic telephony (currently BT and Kingston) to bill their customers
on behalf of other providers of telephone directories if they continue
to use the ordinary telephone bill for charging for phone books.
13 For a summary of key conclusions and proposals
see the tables at the end of Chapters 2 to 7.
Chapter 1
Introduction
Purpose
of this Document
1.1 The purpose of this document is to review the
current provision of directory information services and products to customers
and propose changes.
1.2 Directory information is part of the set of
information telecommunications companies hold about customers. This information
is used to produce printed phone books and provide directory enquiry services.
To give an indication of the size of this market, in 1995/96, 605.5 million
calls were made to BT's directory enquiry service and BT printed 19 million
phone books. Directory information is also used to produce CD-ROMs and
provide on-line non operator assisted directory enquiry services. The telecommunications
industry derives a direct benefit from the use of directory information
services and products in that they generate revenue from follow on calls
as a result of successful directory searches. Comprehensive directory services
maximise the benefit the community at large and businesses derive from
the telecommunications system.
1.3 Oftel published a consultative document on
this subject in 1995, Uses of Directory Information, which made
proposals to enable competition to emerge in the market for databases holding
compiled directory information. The responses to the consultation, follow-up
industry workshops and discussions with interested parties opened up a
broader range of issues than those considered in the previous consultative
document. This document aims to address these matters and take account
of current and proposed European legislation affecting the use of residential
customers' directory information and the provision of directory information
services.
Oftel's Objectives
1.4 Oftel's objectives are to:
(i) improve the quality, variety and choice of
directory information services and products available to customers by removing
barriers to entry so that fair and effective competition can emerge.
(ii) ensure that customers have access to more
comprehensive directory services and products.
(iii) address the privacy concerns of residential
customers regarding the way their directory information is used.
Key Terms
1.5 The following key terms are used in this document
(for further terms and abbreviations see the glossary):
Legislative
Framework
1.6 Annex A provides details of the legislative framework.
The Director General of Telecommunications has a statutory duty (which
is shared with the Secretary of State) under the Telecommunications
Act 1984 to ensure that there are provided throughout the UK directory
information services to satisfy all reasonable demand. Provision of directory
information services to customers is covered by licence obligations
falling on all Public Telecommunications Operators (PTOs). These obligations
require all PTOs to provide their customers with access to a directory
information service covering their voice telephony customers and the voice
telephony customers of other operators with whom that PTO interconnects,
to the extent that interconnecting operators make this information available.
(Annex A provides a summary of PTO licence obligations.)
1.7 Provision of directory services is also covered
by Article 16 of the Voice Telephony Directive (VTD) and Article
6 of the proposed Amending Voice Telephony Directive (AVTD) which
will replace it. The provisions of the former only apply to BT and Kingston
Communications. The latter will impose some additional obligations which
extend the coverage of directory information services beyond voice telephony
numbers to include other types of numbers from the National Numbering Scheme
(eg fax numbers, paging numbers etc). These additional obligations are
discussed in Chapter 5.
1.8 Data protection legislation regulates those
holding personal data which includes directory information about residential
customers and those business customers who are sole traders and partnerships.
The Data Protection Act 1984 is being replaced by new primary legislation
to implement the EU Data Protection Directive by October
1998. The implications of data protection legislation for the use of residential
directory information are considered in Chapter 4. Article 11 of the proposed
Data Protection in Telecommunications Directive covers directory
information. The provisions of this are considered in Chapters
4 and 5.
Overview
of Current Arrangements
1.9 Figure 1.1 shows the current arrangements for
providing directory information services and products to customers. There
are four stages involved:
-
Firstly, the collection of raw directory information
from customers which is usually done by the PTO or service provider with
whom the customer has a contract at the time when the customer orders telephone
service.
-
Secondly, the aggregation of directory information
from different telecommunications companies into core databases.
At present there is only one core database with aggregated directory information
on customers of different telecommunications companies. This database is
owned and managed by BT and is known as the Operator Services Information
System (OSIS). Not all operators input their customers' directory information
on OSIS. Kingston, Vodafone and Orange maintain separate directory databases
of information on their customers. Although all PTOs can, under their licence,
obtain directory information from interconnecting PTOs to establish their
own directory databases of aggregated PTO information, only BT does so.
-
Thirdly, the creation of product databases suitable
for various uses which are produced by downloading directory information
from OSIS. Downloads are used by BT to produce:
Figure
1.1 Current arrangements for providing directory information services and products
1.10 The proposals in this document do not affect
the provision of the 999 service which is organised separately from the
provision of directory information and involves use of physically separate
databases which are subject to different regulation.
Timetable
1.11 Oftel is working to the following provisional
timetable for the implementation of the proposals discussed in
this document:
1.12 Oftel's aim is that following consultation on
these proposals any changes should be implemented as soon as possible so
that consumer benefit can be maximised. However, Oftel recognises that
a number of the proposals in this document will require operators to make
system changes. Operators are invited to respond with an indication of
reasonable time scales for implementation of these changes (see question
16 in Chapter 8).
Structure
of this Document
1.13 Chapters 2 and 3
discuss the extent to which the current arrangements for providing directory
information services and products meet customers' needs and the problems
with the current arrangements from the telecommunications industry's perspective.
They set the context for the needs and problems which Oftel's proposals
in later chapters aim to address.
1.14 Chapter 4 sets out
Oftel's proposals on the uses of directory information which have been
drawn up in close consultation with the Data Protection Registrar.
1.15 Chapter 5 covers
Oftel's proposals to improve the comprehensiveness of directory services
for customers and to increase the choices available to them about how their
directory information can be used in an attempt to reduce the proportion
of customers opting to be ex-directory.
1.16 Chapter 6 deals with
access to directory data and directory databases which need to be provided
on fair and non-discriminatory terms if competition is to emerge in the
provision of services and products to customers. Chapter
7 sets out Oftel's proposals for removing the barriers to entry to
enable competition to emerge so that customers have a choice of directory
services and products.
1.17 Chapter 8 provides
an explanation of the draft licence modifications proposed.
1.18 Summary
of the questions to which responses are invited.
1.19 At the conclusion of Chapters 2 to 7 are
summary tables setting out the main issues identified and Oftel's proposals
for dealing with these.
Chapter 2
Customers' needs
Introduction
2.1 This chapter assesses the extent to which the
present arrangements meet the needs of residential and business
customers and considers the need for change to these arrangements from
the point of view of customers. Customers' needs are considered in terms
of:
Residential Customers
2.2 Residential customers may have varying needs
depending on whether they are the subjects of directory searches or users
of directory information services and products. This can lead to some inherent
tensions. For example, whilst some residential customers seek to protect
their personal privacy by not being listed in directories, most customers
want comprehensive directory information services.
Residential customers as the subjects of directory
searches
2.3 Oftel is acutely aware of residential customers' concerns
to preserve their privacy by restricting the use made of their directory information.
Privacy of customers' information was the subject of 1,550 complaints to Oftel
in 1996. Further evidence is the growing proportion of customers who are choosing
to be ex-directory. BT data indicates that the proportion of residential customers
who are ex-directory is 37% at present compared with 24% in 1991. Only 2% have
chosen the directory option of `DQR' which means that the customer's number is
available from operator assisted directory enquiry services but no details are
available in printed directories or other services and products. Figure
2.1 shows the growth in the proportion of ex-directory customers on BT's database
over the last four years. Figure
2.2 gives an indication of the geographic variation in the proportion of customers
who are ex-directory which peaks at 56% in London.
Figure
2.1 Proportion of residential customers who have chosen ex-directory and DQR
status
Figure
2.2 Geographic variation in residential ex-directory levels
2.4 Customers who do elect to be listed in a directory
do so on the basis of their expectations as to how their directory information
will be made available. Qualitative research conducted by Oftel (SRU 1993)
revealed that there was considerable resistance to any changes which might
make it easier for the telemarketing industry to contact residential customers
or increase the chance of nuisance calls being made. Respondents said that
they would be more likely to go ex-directory if this happened.
Residential customers as users of directory information
services
2.5 Residential customer feedback to Oftel via complaints,
enquiries and market research suggests that they seek directory information
services which are comprehensive, accurate, up-to-date, convenient and
value for money.
2.6 The present arrangements provide directory
information services and products which are more or less comprehensive
in terms of their coverage of voice telephony numbers for fixed line customers
who have agreed to be listed in the phone book and/or the directory enquiry
service. However, directory information services and products are far from
complete in terms of their coverage of mobile and other types of numbers
(eg personal numbers and fax numbers). BT's directory database (OSIS) contains
25.6 million entries in total of which 22.2m are residential entries and
3.4m are business entries. These are mainly for standard fixed line numbers.
Table 2.3 gives details of number of entries for mobile, fax, freephone
and personal numbers on OSIS.
Table
2.3 Directory entries on OSIS
|
Entries on OSIS |
Estimated numbers
in use |
| Mobile |
42,000 |
7 million |
| Fax |
264,000 |
Unknown |
| Freephone |
17,500 |
100,000 |
| Personal numbers |
100 |
Unknown |
2.7 Market research commissioned by Oftel (NOP
1997) shows that there is customer demand for more comprehensive directory
information services:
2.8 The growing proportion of customers who are choosing
to be ex-directory is, of course, another factor limiting the comprehensiveness
of directory information services and products. Oftel is concerned to ensure
that any changes to directory information arrangements do not give rise
to customer concern about the use of their information which in turn might
cause more people to opt to be ex-directory. In the interests of all customers
using directory information services, the aim must be to stop the growth
in the proportion of ex-directory customers and if possible reduce ex-directory
levels.
2.9 In addition to customer benefit from being
able to contact more people connected to the telecommunications network,
there is an economic benefit to having more comprehensive and therefore
more useful directory information services. The telecommunications industry
as a whole benefits because of the additional network revenues generated
from successful directory searches leading to follow-on calls.
2.10 The current arrangements provide customers
with a limited choice of services and products. For example:
2.11 The range and variety of directory services
and products available in other countries is unavailable in the UK. For
example, residential directory information is unavailable on the Internet,
there is only one CD-ROM product on the market containing residential information
(BT's Phone Disc), and only one on-line service (BT's Phone Base). Opening
up the market to competition might lead to the development of a range of
new services and products of benefit to customers. These might include,
for example:
2.12 Recent research commissioned by Oftel amongst
residential customers shows that generally customers are satisfied with
the services they receive - 76% of customers were very or fairly satisfied
with their phone book, whilst 92% of customers who used the DQ service
were very or fairly satisfied with that service (NOP 1997). It is to be
expected that customers may not express dissatisfaction with their phone
book as it has been provided in the same way for so long. The common perception
is that the phone book is provided `free' and on this basis it is generally
valued. There is low understanding and awareness of the possible range
and quality of directory alternatives because people have generally had
no experience of such options.
2.13 Complaints and enquiries to Oftel do, however,
suggest some customer dissatisfaction with phone books. 400 complaints
were received about phone books in 1996. These largely related to incorrect
and missed entries, format problems, delivery delays, and timing. A common
theme was concern about the length of time associated with correcting and
updating phone books, and how quickly they are outdated, being published
by BT only every 18 months.
2.14 Oftel received recurring complaints from
cable customers who were experiencing difficulty being listed in and receiving
a phone book. This issue also emerged in an Oftel survey of customers who
had switched to cable (BMRB 1995). This found that a significant minority
of residential customers had problems with directory services - 11% had
experienced problems receiving a phone book and 7% complained that their
new number had not been listed in the phone book. Oftel's investigation
of the complaints it received from cable customers shows that there are
a variety of reasons for these problems which are not solely caused by
BT delays.
2.15 Oftel receives a relatively low level of
complaints about directory enquiry services - 152 complaints in the last
12 months. The most common reason was cable customers complaining about
late or absent entries from BT's directory enquiry service. Again Oftel's
investigations revealed a number of reasons for this. Other complaints
included BT providing the wrong number, customers being incorrectly listed,
unhelpful DQ operators and being charged when the directory search was
unsuccessful or the wrong number was provided.
2.16 There is some research evidence of demand
for change:
2.17 All PTOs are required to provide blind and disabled
customers who are unable to use a telephone directory with a free directory
enquiry service. The proposals in this document will not affect this service
but aim to enhance it. Oftel will be consulting separately on the provision
of telecommunications services for disabled customers later this year.
2.18 At present the free DQ service is usually provided
by PTOs through a discrete access number (195) and unauthorised use of this
service is limited by the issue of personal identification numbers (PINs) to
eligible customers. PTOs maintain databases of PINs. However, because each database
is unique to each PTO, problems arise if a customer wishes to use a DQ service
from equipment connected to another network. In such cases free DQ service may
be refused or unwieldy ad hoc arrangements used to consult the `sponsoring'
PTO for validation. The Advisory Committee on Telecommunications for Disabled
and Elderly People (DIEL) has identified this as a problem and recommended that
it could be alleviated by requiring PTOs to pass on PINs to all those providing
DQ services. Oftel's proposals in Chapter 6 (paragraph
6.16) address this recommendation. In addition DIEL recommended that if a customer
is a textphone user these details should be available from the DQ service in
the same way as a particular number of another customer is associated with a
mobile line, a fax line and so on. This recommendation is also addressed by
Oftel's proposals in Chapter 6 (paragraph 6.16) and
by the requirements in the draft Code of Practice at Annex
C.
Business Customers
2.19 The needs of business customers are many and
varied. Most business customers are dependent on customers being able to
obtain directory information in order to contact them. Businesses are also
often major users of directory information services and tend to seek a
greater range of options with regard to enhanced and innovative directory
information services and products.
Business customers as the subjects of directory searches
2.20 In contrast to the privacy concerns of residential
customers, business customers generally seek to promote their directory
information and have it as widely available as possible. However, some
business customers may have privacy concerns.
2.21 Any problems with directory listings can
cause major difficulties for businesses who are dependent on their customers
being able to keep in touch. Survey evidence (BMRB 1995) indicated business
customers who had switched to cable were more likely to have experienced
problems with directory information services. A fifth (19%) said that they
were aware of their customers having problems getting their number from
directory enquiries; 9% said that they had experienced problems getting
hold of directories and a similar proportion said that they had difficulty
getting listed in the phone book. This reflects the difficulties surrounding
the entry of other operators' data onto BT's database which are discussed
in the next chapter.
Business customers as users of directory information
services
2.22 Business customers seek comprehensive, accurate
and up to date directory information services. Increasingly they seek more
innovative and enhanced directory information products. Often their demands
are for bulk directory searches to enable the addition of telephone numbers
to name and address lists of customers efficiently and cheaply. Companies
which are heavy users of directory enquiry services may use BT's CD-ROM
or on-line service as these are more cost effective for bulk use. Comprehensive
directory services are important for private and public sector business
users so that they can contact their customers.
2.23 BT has copyright licensing agreements with
other companies for use of business directory information. Under these
agreements BT passes on business directory information to companies other
than PTOs. This has facilitated the development of a range of services
and products containing business directory information, including Thomson's
printed directories, classified directory information on the Internet,
freephone services offering classified directory enquiry services and a
choice of CD-ROM products. The choice and variety that has emerged in this
market is not the result of competition between PTOs, rather competition
from independent service providers.
2.24 Whilst a variety of directory information
services and products containing business directory information have been
developed, there are few services and products containing residential directory
information. Some business demand for new residential directory information
products and services is dependent on being able to use such information
in new ways which may raise serious privacy concerns for residential customers.
For example, business users have expressed an interest in using phone numbers
to generate names and addresses (ie a reverse search directory) and in
being able to list directory entries on a street by street basis for telemarketing
purposes. The uses of directory information and customers' privacy concerns
are discussed in Chapter 4.
Summary of Needs
2.25 The needs of residential customers for privacy
and the needs of both residential and business customers for comprehensiveness,
innovation, choice and value for money are the key issues Oftel is seeking
to balance in considering the most appropriate regulatory framework for
the provision of directory information services and products. Chapters
4 to 7 set out Oftel's proposals for balancing these needs by addressing
customers' privacy concerns about the use of their directory information
and opening up the market for competition so that there is more choice
of services and products. Table 2.4 summarises the needs identified in
this chapter and Oftel's proposals which are discussed in later chapters.
Table
2.4 Summary of customers' needs and Oftel's proposals for dealing with
these
Customers
|
Needs
|
Problems
|
Proposals for change set
out in later chapters |
| Residential
|
Protection of privacy
|
Concern that directory information will be used
in ways that customers do not expect.
Concern at use of directory information for telemarketing
Lack of choice about how directory is used
|
Chapter 4 - A Code of
Practice setting out how directory information can be used.
Chapter 4 - A choice
for customers to opt out of their directory information being used for
direct marketing.
Chapter 5 - Greater choice
for customers about how their directory information information can be
used.
|
Residential and business
|
More comprehensive directory services
|
37% of residential customers are ex-directory.
(56% in London)
Poor coverage of directory information relating
to numbers other than voice telephony.
Only 0.6% of mobile numbers in use are
available from most DQ services.
|
Chapter 5 - More directory
status options for customers which might reduce demand for full ex-directory
listing.
Chapter 5 -Implementation
of EU legislation which requires the inclusion of other types of numbers
(eg fax, paging numbers etc) in directories and directory enquiry services.
Chapter 5 - The
inclusion of more mobile numbers in directory services.
|
| Residential and business
|
Greater choice of directory services and products
|
Customers have no choice of alternative DQ services
or phone books
Customers have no choice of receiving and paying
for phone books.
|
Chapters 6 and 7 - Removal
of barriers to entry so that PTOs and independent service providers can
compete effectively
Chapter 7 - BT and Kingston
to unbundle phone books from line rental so that customers have a choice
of taking phone books
|
Chapter 3
Problems
from an industry perspective
Introduction
3.1 This chapter considers the extent to which current
arrangements for the provision of directory information services and products
meet the needs of:
Licensed Operators
3.2 Concerns that PTOs have expressed about the provision
of directory information services and products largely stem from BT's control
of OSIS. The majority of PTOs rely on OSIS for inputting their customers'
directory entries, for the provision of DQ services in order to fulfil
their licence obligations, and for the production of phone books for their
customers. The main concerns of other operators include:
3.3 Many other operators believe that the solution
to these problems is for a competing directory database or databases to
emerge not run by their principal competitor. Or for there to be a single
database controlled independently of BT. While Oftel can remove barriers
to entry there is no guarantee how quickly a competitor to BT's database
will emerge. There is therefore a need for fair and transparent arrangements
whilst BT remains dominant.
Independent
Service Providers
3.4 The principal concern of independent service
providers is that BT has refused to provide them with downloads of residential
directory information - either the directory information on BT's customers
or the whole of OSIS which includes other PTOs' directory information -
so that they can create a directory database for interrogation as they
wish. Also BT does not provide access to DAS (the database which BT uses
to provide operator assisted DQ services) for the purpose of providing
competing operator assisted DQ services. Under its licence, BT is only
obliged to supply interconnecting PTOs with directory information on this
database, it is not required to provide this information to independent
service providers. BT has been exploring the provision of residential directory
information to independent service providers but is concerned about adequate
safeguards for customers' privacy, and its contractual obligations to its
customers (see Chapter 4 paragraph 4.9).
3.5 Independent service providers and end customers
have access to Phone Disc (BT's CD-ROM) and Phone Base (BT's non-operator
assisted on-line service). The latter is available through BT's resellers
licence which enables independent service providers to offer bulk directory
information services to append phone numbers to clients' name and address
lists. However, it cannot be used to provide an effective operator assisted
DQ service because: it does not allow fast enough searches; it excludes
ex-directory customers' names and addresses which are used by DQ operators
to confirm to an enquirer that the number they wanted is ex-directory;
and the level of on-line charges associated with Phone Base make it difficult
to offer a competitive operator assisted service. Phone Disc is unsuitable
to provide an operator assisted DQ service because it is out of date as
soon as the CD-ROM is produced.
3.6 Independent service providers are able to
purchase business directory information to offer a range of services and
products. However, they are unable to compete effectively in the provision
of directory databases, DQ services, phone books, on-line services or CD-ROMs
using residential directory data as they face a number of other barriers
to entry which are discussed in Chapters 6 and
7.
Summary of Problems
3.7 Table 3.1 summarises the problems identified
in this chapter and Oftel's proposals for dealing with these issues which
are set out in later chapters.
Table 3.1 Summary of problems faced by the
industry and Oftel's proposals for dealing with these
| Company |
Problem |
Proposals set out in later chapters |
PTOs
|
Concerns about the arrangements for inputting
information to OSIS and accessing information from DAS whilst BT is dominant.
|
Chapter 6 - proposals
for fair and non-discriminatory arrangements for input to OSIS and access
to DAS and OSIS until the markets for core and product databases are competitive. |
PTOs
|
Lack of choice of agency DQ services and alternative
phone book suppliers as independent service providers unable to enter the
market.
|
Chapter 7 - safeguard
caps on BT's agency DQ and phone book charges until markets are competitive.
Chapter 6 - fair and
non-discriminatory access to directory information in core databases and
product databases for independent service providers to develop agency services
for other operators.
|
Independent service providers
|
Lack of access to downloads of residential directory
information and lack of access to DAS.
|
Chapter 6 - PTO licences
modified to require supply of directory information to independent service
providers. BT obliged to supply downloads of OSIS and access to DAS to
independent service providers until these markets are competitive. |
Independent service providers
|
Barriers to entry in the provision of DQ services,
phone books and other directory services and products. |
Chapter 7 - identification
of barriers to entry and Oftel's proposals for removing these.
|
Chapter 4
Uses
of directory information
Introduction
4.1 Currently, restrictions on the use of residential
customers' directory information are imposed by BT limiting access to these
data. BT has taken action against several companies which have used directory
information, without BT's agreement, to develop products which give rise
to privacy concerns. If directory information is made more widely available
to other companies to enable the provision of a wider range of services
and products it may dampen demand for illicit uses which fall outside the
contractual arrangements which BT has in place with those it supplies information
to.
4.2 In a competitive directory information market,
it would be inappropriate for BT to act as the arbiter of how directory
information can be used. Instead there needs to be a common set of rules.
This chapter sets out Oftel's proposals concerning the use of customers'
directory information taking account of the privacy concerns of residential
customers. Oftel's proposals have been developed in close consultation
with the Data Protection Registrar. The main focus of this chapter is residential
directory information since most business customers do not have the same
privacy concerns.
4.3 The following issues are covered in this chapter:
Data Protection
Legislation
4.4 The Data Protection Act 1984 (DPA) regulates
the holding of `personal data', that is information recorded on computer
about living identifiable individuals. The DPA does not apply to information
about businesses, although data relating to partnerships and sole traders
may be personal data within the meaning of the DPA. Therefore, the DPA
applies to directory information about residential customers and some business
customers (partnerships and sole traders) which is held on computer.
4.5 The Government is introducing new primary legislation
on data protection to implement the EU Data Protection Directive (DPD) which
extends data protection requirements to some manually held records (see Annex
A). The discussion below on the application of the DPA to uses of directory
information will apply under the DPD which also requires that personal data
must be processed fairly and lawfully. In addition the proposed Data Protection
in Telecommunications Directive contains provisions to give customers choices
about how their directory information is used. These are set out in Annex
A and discussed later in this chapter and in Chapter
5.
4.6 The DPA/DPD give rights to individuals about
whom information is recorded on computer and held in manual records. They
may find out what information is held on them, challenge it if appropriate
and claim compensation in certain circumstances. The DPA/DPD place obligations
on those who record and use personal data (`data users'). They must be
open about that use (through the Data Protection Register) and follow sound
and proper practices (the Data Protection Principles).
4.7 There are eight Data Protection Principles set out
in the DPA (see Annex
A). Any data user must comply with these Principles. If a registered data
user contravenes the Principles the Data Protection Registrar (DPR) can take
enforcement action against them. Whilst all the Principles are of relevance
to the processing of directory information, the DPR considers that the First
Data Protection Principle is of particular relevance to considerations about
access to, and uses of, directory information. The First Principle states that:
"The information to be contained in personal data shall be obtained, and
personal data shall be processed, fairly and lawfully".
"Fairly obtained"- Providing directory data to other
companies
4.8 In judging whether personal data have been obtained
fairly the DPR would consider whether the individual to whom the data relates
understood the purposes for which the data would be held, used and disclosed
and was informed of any non-obvious purposes before the data were obtained.
The DPA provides that personal data are always to be treated as fairly
obtained when the person from whom they are obtained is required by or
under an enactment to supply such data. As PTOs are required by licence
granted under the Telecommunications Act to supply directory information
to interconnecting PTOs, directory information obtained under this arrangement
would be regarded as being obtained fairly. This would also apply if licence
modifications were agreed by PTOs which required them to supply directory
information to independent service providers for the purpose of providing
directory information services and products, as proposed in Chapter
6.
4.9 Even without licence modifications, giving
others access to residential customers' directory information would be
considered by the DPR to meet the requirements of being obtained fairly
in terms of the First Data Protection Principle provided customers were
made aware of this possibility at the time their consent for a directory
entry was obtained. This already occurs for BT customers and Oftel understands
it also occurs for the customers of other operators. For example, BT's
current customer order form, which forms part of the contract with customers,
states that "we intend to make the Phone Book entry details of our customers
available to other firms who provide phone number services. If you do not
want us to release your Phone Book entry details to these firms please
let us know...". This form of contract has been used since 1984. BT's
pre-1984 contracts did not contain such wording. If customers do not wish
to have their phone book details passed on they must opt to be ex-directory.
"Fair processing" of residential directory information
4.10 The DPR's view is that the requirement to process
directory information fairly means that directory information should only
be used in ways likely to have been expected by customers unless the customer
has consented to other uses. When customers decide to have a directory
entry in the phone book and/or directory enquiry services, they do so based
on an expectation of how their information will be used. Data used in ways
that the customer does not expect could be regarded as being processed
unfairly in terms of the DPA.
4.11 Customers' expectations of how their directory
information will be used are based on previous experience and are broadly:-
4.12 Customers who have a directory entry do not
expect:
4.13 The DPR's view is that there is potential for
unfairness if proposed changes lead to directory information being used
in ways unexpected by customers without their knowledge and informed consent.
Thus, there are two options for ensuring that residential directory information
is processed fairly:
4.14 Broadening access to residential directory information,
to enable competition in directory services, as outlined in Chapters 6
and 7, need not involve it being used in ways that customers do not expect.
Contacting all residential customers solely for the purpose of obtaining
their consent to new uses of their directory information would involve
considerable expense and might significantly increase the cost of directory
data. It could result in customers being recontacted on numerous occasions
by different companies about different uses of their directory information.
This might cause customer anxiety and annoyance and increased migration
to ex-directory status which would reduce the usefulness of directory information
services for all customers. For these reasons, permitting companies
to re-contact all residential customers is considered by Oftel to be unnecessary
and undesirable. Exceptions to this are proposed later in Chapter 5
where it is suggested that it may be appropriate for PTOs to recontact
their ex-directory customers in order to offer them a wider range of choices
about the use of their directory informationand in relation to a direct
marketing opt out in this chapter.
4.15 It is recognised that circumstances could
arise in which the customer may contact the company using directory information
and it might be appropriate to seek the customer's consent for a particular
use of directory information at this time. The customer might well consider
it acceptable for their directory information to be used for another purpose
and should have the option of refusing. In such circumstances, where the
customer initiates contact rather than the company using the directory
information, this is less likely to result in customer annoyance or anxiety.
Oftel proposes that so long as a customer's prior and informed consent
for a particular use is given, as a result of a contact initiated by the
customer, then that use would be regarded as acceptable.
Uses
of Residential Information
4.16 Oftel proposes that residential directory
information should only be permitted to be used for the creation of directory
databases for the following purposes, unless the customer's prior and informed
consent has been obtained for other uses (as discussed, consent should
only be obtained where the customer contacts the company using the data;
not vice versa):
4.17 It has been suggested that customers should
be able to choose to have a directory entry but not to have their directory
information made available to other organisations. Such an option might
help to limit the number of customers choosing to go ex-directory. However,
allowing customers to choose who receives their directory information would
result in an uneven playing field between companies offering directory
information services and products. It would also hamper the emergence of
competition between providers offering comprehensive directory information
services and products. Therefore, Oftel proposes that customers should
not be given the option of which organisations have access to their directory
information.
Uses of
Business Information
4.18 BT already has contractual agreements setting
out a framework of permitted uses of business directory information for
other companies wishing to use this information. The restrictions and permitted
uses are similar to those proposed above for residential customers' directory
information except that BT's contract for the use of business directory
information allows the recipient of the data to recontact all business
customers to obtain consent for other uses to be made of their directory
information. For example, Thomson and Yellow Pages use this information
to sell businesses adverts in their classified directories. Oftel is not
aware of any concerns about uses of business directory information permitted
by BT from the point of view of organisations wishing to use the data.
Thus Oftel does not propose any changes to the existing rules governing
the use of business directory information. These have been included in
the Code of Practice discussed later in this chapter. Oftel invites
comments from respondents on this approach.
4.19 At present if business customers do not wish
to be recontacted by the classified business directory publishers they
have to opt to go ex-directory. Some partnerships and sole traders have
complained to the Data Protection Registrar about being recontacted by
the classified directory publishers. The Data Protection Registrar has
suggested that business customers should be given the option of not being
recontacted by the publishers of classified directory products. This is
probably best dealt with by giving business customers that option at the
time they choose their directory entry. This is covered by proposals in
Chapter 5.
Ex-Directory
Customers' Information
4.20 The treatment of ex-directory information raises
issues as to how directory enquiry services should operate. A key question
is whether callers to DQ services should be able to establish that the
number they seek exists but is ex-directory. Oftel is interested in how
important this current feature of directory enquiry services is to all
customers. This is one consideration in determining any requirements for
PTOs to pass on any information about ex-directory customers to other providers
of directory enquiry services.
4.21 Previously Oftel had suggested that all PTOs
should be required to pass on their ex-directory customers' names, addresses
and telephone numbers to other providers of directory enquiry services.
The reason for this was to enable other providers to offer a directory
enquiry service equivalent to that of BT. In light of concerns about ex-directory
customer privacy, Oftel has considered two alternative options:
Option A
Option B
4.22 Oftel invites comments from consumer representatives
and providers of directory information services on whether Option A or
B regarding the treatment of ex-directory information should be pursued.
4.23 BT's OSIS/DAS databases currently contain
telephone numbers for ex-directory customers which could give it an advantage
over competitors. For example, where an enquirer convinces a BT supervisor
that there is a life and death situation, the supervisor will sometimes
connect the call to an ex-directory customer without revealing their number
_ this occurs approximately 1,000 times per annum. Oftel will require BT
to develop alternatives which are not linked to its directory service.
Oftel considers in circumstances such as these, it would be inappropriate
for third parties to make decisions about the release of ex-directory customer
details. Rather it should be a matter for the PTO with whom the customer
has a contract. Oftel therefore proposes that in such circumstances any
third party DQ provider should refer the caller to the relevant PTO. Each
PTO should have arrangements in place to handle such calls separately from
any directory enquiry service and these arrangements should involve, in
appropriate circumstances, connecting the call to the ex-directory customer
without disclosing the number to the enquirer so as to preserve the privacy
of the ex-directory customer's number.
4.24 Oftel proposes that complete directory
information for customers who have opted for DQR status (not listed in
the phone book but available from directory enquiry services) would be
made available to PTOs and independent service providers. However,
those providing directory information services would only be able to use
these names, addresses and phone numbers for purposes which customers have
agreed to (ie not for printed or electronic directories). When a broader
range of new directory status options is introduced, as proposed in Chapter
5, organisations would have to restrict their use of such data to the
particular purposes which the customer has agreed to.
Code of Practice
4.25 Oftel has considered various options for developing
and applying rules on the use of directory information:
4.26 The Data Protection Principles are necessarily
general. The Data Protection Registrar takes the view that wherever possible
it is preferable to draw up sector specific Codes of Practice for different
areas of activity based on the Data Protection Principles. Oftel considers
that a specific Code of Practice on the use of directory information is
the preferred way forward for the following reasons:
4.27 As the second and third reasons equally apply to business
as well as residential directory information Oftel proposes that the Code of
Practice covers the use of all directory information. Annex
C sets out a draft Code of Practice on proposed uses of directory information
for comment. Oftel has drawn this up in consultation with the Data Protection
Registrar.
4.28 Oftel has considered two approaches to enforce
the proposed Code of Practice on recipients of residential directory information:
4.29 Whilst the Telecommunications Act licensing
option has the attraction that Oftel can take direct enforcement action
against those in breach of their licence, Telecommunications Act licences
only apply to those running a telecommunications system. Many of the uses
of directory data outlined above, such as compiling directory databases,
and producing printed directories and CD-ROMs, would not be covered. As
only some uses of directory information would be covered by the Telecommunications
Act licencing route Oftel considers that this would not be the best way
forward.
4.30 Oftel therefore proposes that PTO/other
licensees' licences should be modified to require PTOs/other licensees
to adhere to the Code of Practice covering the use they make of directory
information. Proposed licence modifications would also require PTOs/other
licensees to secure adherence to the Code of Practice by those they supplied
directory information to. Oftel could then take enforcement action
against PTOs if they failed to comply with the Code of Practice. PTOs/other
licensees could take action for breach of contract against those they supplied
information to. The Data Protection Registrar would also have a role in
taking enforcement action against breaches of the Code of Practice. If
a PTO or those to whom PTOs provided directory information, used directory
information in ways not permitted by the Code of Practice imposed via a
licence condition or a contractual agreement, this would involve unlawful
processing in breach of the First Data Protection Principle. If customers'
directory information were subsequently processed in violation of the Code
of Practice by a company or individual that was not subject to a licence
or contract, they would be likely to have unfairly processed personal data
in breach of the First Principle. Under such circumstances the Data Protection
Registrar could take enforcement action.
Use
of Directory Information for Telemarketing
4.31 The proposed Data Protection in Telecommunications
Directive will entitle residential customers to indicate that their directory
information may not be used for direct marketing (Article 11, paragraph
1). This would include the use of directory information for telemarketing
and direct mailing purposes.
4.32 Unsolicited telemarketing is of concern to
some residential customers. Oftel received around 1,000 complaints relating
to telemarketing calls in the last 12 months, and the volume of complaints
has shown a marked increase in the last year. One of the reasons why some
customers opt to go ex-directory is to reduce telesales calls. In research
commissioned by Oftel (NOP 1997) 51% of ex-directory customers said that
they had chosen ex-directory status to avoid nuisance calls, which may
include telesales calls, and 19% specifically mentioned (unprompted) avoiding
telesales calls as a reason for choosing to be ex-directory.
4.33 To date the approach taken to address this
issue has been by a voluntary industry self regulation initiative. The
Direct Marketing Association (DMA) established the TPS in January 1995.
The TPS is a service customers can join to help reduce the level of unwanted
telemarketing calls (it effectively allows customers to opt out of receiving
some, but not all, telemarketing calls). The TPS does not eliminate unwanted
telemarketing calls completely but can help reduce the number of unwanted
calls customers receive by arranging for customers' telephone numbers to
be removed from lists used by many of the companies engaged in telemarketing.
In order to register with the TPS customers need to be aware of its existence
and contact their telephone company. A list of people registered with the
TPS is then made available so that companies can screen their telemarketing
lists against this and remove those who are registered with the TPS. As
at May 1997, 149,726 customers had registered with the TPS. Research commissioned
by Oftel shows that only 10% of residential customers were aware of the
existence of the TPS, and that 49% of those who were unaware of it would
be interested in joining a scheme to reduce the number of unsolicited telemarketing
calls they receive (NOP, 1997). The DMA also set up a Fax Preference Service
(FPS) in March 1997 which gives customers using fax machines in their homes,
the opportunity to reduce the chances of receiving unsolicited advertising
communications by fax. The FPS operates along similar lines to the TPS.
4.34 In order to meet the requirements of the
proposed Data Protection in Telecommunications Directive and, in an effort
to reduce the proportion of residential customers opting to go ex-directory,
Oftel proposes that by October 1998 (the date for implementation of
the Data Protection in Telecommunications Directive):-
Summary of Proposals
4.35 Table 4.1 summarises the main proposals in this
chapter.
Table 4.1 Summary of Oftel's proposals
| Issue |
Oftel's proposals |
Principles for the treatment of residential customers'
directory information
|
Residential directory information should only
be used in ways customers expect unless data users have obtained customers'
prior and informed consent to other uses.
Customers should not be able to choose to restrict
the availability of their directory information to particular companies. |
Uses of directory information
|
A Code of Practice (draft at Annex
C) setting out permitted uses of residential and business directory
information based on data protection legislation.
Licences of all those entitled to direct allocations
of numbers modified to require adherence to the Code of Practice including
a requirement to secure adherence to the Code of Practice by those to whom
they supply directory information. The Code of Practice would be enforceable
on:
. PTOs/other licensees by Oftel through licence
conditions;
. independent service providers by PTOs/other
licensees through breach of contract; and
. all data users by the Data Protection Registrar
through breach of the Data Protection Principles. |
Treatment of ex-directory customers' details
|
Two options for consultation:
Option A - no details of ex-directory customers
are made available to providers of directory information services.
Option B - ex-directory customers' names and addresses
are made available, but not their phone numbers, only for use in connection
with directory enquiry services. |
Use of directory information for telemarketing
|
All customers to be given the opportunity to
opt out of their directory information being used for direct marketing.
This option to be advertised effectively to all existing customers.
A "no direct marketing " flag to be attached to
relevant directory entries on all directory databases and products derived
from those databases.
The Code of Practice to prohibit use of such entries
for direct marketing. |
Questions
(1) Comments are invited on the draft Code of Practice at
Annex C.
(2) Which of the following options do respondents
favour regarding the treatment of ex-directory customers' information:
Option A - no details of ex-directory customers
are made available to providers of directory information services.
Option B - ex-directory customers' names and addresses
are made available, but not their phone numbers, only for use in connection
with directory enquiry services.
(3) Do respondents agree with Oftel's proposals for
enforcing the Code of Practice by modifying PTO licences (and the licences
of those entitled to direct number allocations) to require adherence to
the Code of Practice and to secure adherence with the Code by those they
supply directory information to?
(4) Do respondents agree with Oftel's proposals
at paragraph 4.34 relating to the use of directory information for direct
marketing?
Chapter 5
More
comprehensive directory services
Introduction
5.1 Customers require comprehensive, accurate and
up-to-date directory information services and products and may be frustrated
when these are unavailable. They require convenient access to directory
enquiry services and are concerned that any policy changes do not fragment
the comprehensiveness of the services that are currently available. This
chapter puts forward proposals to improve the comprehensiveness of directory
services and products provided to customers. It covers the following topics:
Widening
the Choice of Directory Status Options
5.2 The trend of an increasing proportion of customers
opting to go ex-directory is of concern since it reduces the usefulness
of directory services and products for all users. It was noted in Chapter
2 that currently most fixed line customers have the choice of three
directory status options (full listing, DQR (i.e. listing in directory
enquiry services but not in the phone book) or ex-directory). It may be
possible to attract more customers back into a directory service, and to
reduce the proportion of new customers opting to go ex-directory, by increasing
the range of options available and tailoring these to address the privacy
concerns of customers and their motivations for choosing to be ex-directory.
5.3 The proposed Data Protection in Telecommunications
Directive (see Annex
A) requires that directory information is limited to what is necessary to
identify a particular customer unless the customer has given their unambiguous
consent to the publication of additional personal data. It also gives customers
a number of choices concerning their directory entry including:
5.4 Table 5.1 shows the results of research commissioned
by Oftel on the reasons why residential customers
opt to be ex-directory.
Table 5.1 Reasons for choosing to be ex-directory
| Unprompted reason |
% of respondents |
| To stop nuisance calls |
51 |
| Privacy |
28 |
| So that only people who know me can phone me
up |
24 |
| To stop telesales calls |
19 |
| Do not want to appear in the phone book |
10 |
| So people can't find my address |
7 |
| Because of the job I do |
7 |
Sample: 497 respondents who were ex-directory
Source: NOP 1997 |
5.5 This research also revealed that only 20%
of ex-directory customers were aware of the option of having their details
available from directory enquiry services but not in the phone book (DQR
option). Of those who were unaware 21% would have chosen this option in
preference to being ex-directory had they been aware of it.
5.6 The survey also asked ex-directory customers
whether the following options would encourage them to be listed in the
phone book and/or the DQ service:
Tables 5.2 and 5.3 summarise the results.
Table 5.2 Options that might encourage ex-directory
customers to have their details
available from directory enquiry services
|
% of ex-directory customers who would have their
details available from a DQ service |
| If they were only contactable through a call
completion service (see para 5.6) |
61 |
| If they had the option of saying that their directory
information should not be used by telesales companies |
21 |
| Not having full address listed |
11 |
Sample: 497 respondents who were ex-directory
Source: NOP 1997 |
Table 5.3 Options that might encourage ex-directory
customers to have their
details listed in the phone book
|
% of ex-directory customers who would have their
details listed in the phone book |
If they had the option of saying that their directory
information should not be used by telesales companies
|
15 |
Not having full address listed
|
5 |
Sample: 497 respondents who were ex-directory
Source: NOP 1997 |
5.7 This research suggests that giving customers
a wider range of options about how their directory information is made
available might increase the willingness of ex-directory customers to have
an entry in a directory information service in some form. In particular,
a call completion service might attract three-fifths of ex-directory customers
into a directory service. Given the wider public benefit from being able
to contact more customers, the benefit to the telecommunications industry
of more comprehensive directory services resulting in successful follow-on
calls, and the growing proportion of customers opting to be ex-directory,
Oftel considers that there is a case for all telecommunications operators
recontacting their ex-directory customers to offer them a broader choice
of directory status options and for this broader choice to be available
to all new and existing customers. Providing more varied options may
also lead to the development of more sophisticated services eg call completion
services. PTOs should be able to recover the costs incurred in recontacting
customers from purchasers of the directory information.
