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Canadian Radio-Television and Telecommunications Commission
Attention: Ms. Ursula Menke Secretary General
Dear Ms. Menke:
Re: Public Notice CRTC 2001-56: Reverse Search Directory Assistance
1. We are in receipt of comments from Bell et al, Telus, and SaskTel in this proceeding. The following reply comments are made on behalf of Action Réseau Consommateur, the Consumers’ Association of Canada, and the National Anti-Poverty Organization (“ARC et al”), in response to the above-noted public notice.
Reverse Directory Services are privacy invasive
2. Bell et al argue that reverse directory services are privacy enhancing, rather than privacy invasive. ARC et al appreciate the advantages that such services provide to persons who wish to discover the identity and/or address of callers or others for whom they have only a telephone number. However, to characterize such information retrieval as privacy-enhancing is to stretch the definition of privacy beyond its normal meaning. Moreover, it focuses entirely on the needs of the information-seeking party, while ignoring the needs of the party whose information is being sought from a third party without their knowledge.
3. Some individuals have legitimate needs to remain anonymous, or to keep their location confidential. Those seeking refuge from abusive relationships or stalkers clearly need to be able to control the availability of such information. Consumers seeking information on sensitive topics such as personal health advice may not want their identity or address made known to the agency they are consulting. Social workers and others who deal professionally with troubled persons may not want their home addresses publicly available. It is essential that such persons are able to maintain their privacy without extra effort or expense. Reverse directory services threaten to further erode the legitimate privacy needs of consumers.
4. For these reasons, ARC et al submit that the damage to privacy caused by reverse directory services outweighs the informational benefits of the services, such that the public interest is better served by limiting the availability of such services.
5. Should the Commission nevertheless continue to permit the provision of reverse directory services by regulated telephone companies, ARC et al submit at a minimum that: Street address information should not be made available under any circumstances
6. Some telephone companies wish to make street addresses available via reverse directory services. ARC et al strongly oppose such a policy, on the grounds that it would unduly threaten the privacy and safety of subscribers, and is in any case unnecessary: those seeking detailed address information can and should obtain such information from the individual to which it pertains. No party to this proceeding has identified countervailing benefits of such information provision.
Reverse directory services should not be available for the purpose of compiling or updating telemarketing lists
7. ARC et al appreciate that reverse directory services as proposed by the telephone companies in this proceeding are targeted at individual subscribers, and would be neither economic nor practical for use by telemarketers to compile and update marketing lists. However, this may not always be the case. If the service is not intended to be used by telemarketers, ARC et al agree with Bell et al’s suggestion that any such service include a restriction that it is not available for the purpose of compiling or updating telemarketing lists.
Subscribers should be able to opt-out of reverse directory services
8. As stated in their earlier submission, ARC et al urge the Commission to ensure that subscribers are able to opt out conveniently of any reverse directory services, and are made aware of this right. There is no reason to treat reverse directory services any differently from other listing services in this respect.
9. ARC et al agree with Telus that consumer rights in this respect should be the same regardless of the company in question. Other directory publishers and operator service providers should be subject to the same rule requiring meaningful subscriber opt-out opportunities.
All of which is respectfully submitted,
Counsel for ARC et al
cc: Interested parties, PN 01-56