The Growing Importance of Telephone Numbers in the Digital World, Part II

Exploring the policies around recycling telephone numbers.

The Growing Importance of Telephone Numbers in the Digital World, Part II

Shortly after writing about the practice of recycling telephone numbers, “The growing importance of telephone numbers in the digital world”, I reached out to different stakeholders so that I could write a follow up piece.  These stakeholders include privacy commissioners at the provincial and federal level, “the big three” telecom providers, and oversight bodies including the Canadian Radio-Television and Telecommunication Commission (CRTC) and the Canadian Numbering Administrator.

While I wait to receive the last remaining responses to the questions I submitted, I thought it would be a great idea to introduce readers to the Canadian Numbering Administrator and to explore the current policies around the practice of recycling numbers.

What is the Canadian Numbering Administration Consortium?

The Canadian Numbering Administration Consortium, Inc.  was started in 1998 and it operates under the regulatory oversight of the CRTC.  Their primary role is to administer Canada’s telecommunications numbering resources via the selection and funding of a neutral administrator, known as the Canadian Numbering Administrator.

The Canadian Numbering Administrator is responsible for providing numbering administration service to the Canadian telecommunications industry under the regulatory oversight of the CRTC.  Its primary functions revolve around Canadian numbering resource administration, and processing applications for North American Numbering Plan resources and other telecommunications numbering resources.  Another important function involves being a key contributor to the CRTC Interconnection Steering Committee’s working group called Canadian Steering Committee on Numbering.

The CRTC Interconnection Steering Committee is an organization established by the CRTC to assist in developing information, procedures and guidelines as may be required in various aspects of the CRTC’s regulatory activities, and they have a working group called Canadian Steering Committee on Numbering.

The Canadian Steering Committee on Numbering is where numbering issues are actually addressed, and it is comprised of one member from the Canadian Numbering Administrator and one from the CRTC as well as other working group participants who are not publicly listed on their website, but who can be identified by submitting a formal request.

So to sum up, the CRTC oversees the Canadian Numbering Administration Consortium, which selects and funds the Canadian Numbering Administrator, which has a member on the CRTC’s own Interconnection Steering Committee’s working group called the Canadian Steering Committee on Numbering, which is where the work gets done, no doubt in a similarly efficient and timely fashion.

The Canadian Steering Committee on Numbering hosts a public forum where both members of the public and telecom providers can contribute towards policy changes by filling out Task Identification Forms and describing proposed changes to the current guidelines.  After submitting a Task Identification Form, the form is reviewed and voted on by members of the committee.  If the vote passes, the recommendations are shared with the CRTC, and they are included in the new guidelines that get published by the CRTC.

The easiest way to think about all of this is to simplify everything by saying that there are quite a few stakeholders that are involved in the creation of policies and all of them have to be onboard, and they need to have a thorough understanding of the issue for the matter to be addressed accordingly.  However, even if everything makes perfect sense, like updating the guidelines around the practice of recycling telephone numbers, if something like that did not align with the immediate priorities of any of those stakeholders, then it is unlikely that the recommendations would be approved.

The policies around the recycling telephone numbers.

Out of all the interactions I had with the stakeholders who I had identified as having a role to play in the practice of recycling telephone numbers, my interactions with the Canadian Numbering Administrator were by far the most valuable.  In addition to having a ten-minute chat with them, they essentially drew out a web of connections for me, they shared a document that addressed the practice of recycling telephone numbers titled, “Aging and Administration of Disconnected Telephone Numbers”.

The Aging and Administration of Disconnected Telephone Numbers document dated back to 1998, and little seems to have been updated regarding the guidelines around recycling telephone numbers.  What I refer to as “recycling” the document refers to as “reassigning”, and “aging interval” is the term used to describe the specific period of time that a disconnected telephone number is temporarily unavailable.  A number is considered “disconnected” when it is no longer used to forward calls to a customer.  The “aging interval” begins on the date that the number is disconnected and ends after the specific interval is met.  However, the document did not consider “suspended telephone numbers” as “disconnected telephone numbers” for the purposes of this document.

Once we get to the “aging intervals” section of the document, the limited number of months required to pass before a telecom provider is allowed to “re-assign” the telephone number starts to become concerning, as it seems to be more reflective of a non-digital world, and without a consideration for how important telephone numbers have become.  Both a residential wireline (home phone) and wireless (cell phone) numbers are required to be aged for a minimum of one month and a maximum of three months.  Whereas, a business wireline (business phone) number is required to be aged for a minimum of three months and a maximum of twelve months, although a special extension may be granted for three extra months, for a total maximum of fifteen months.  However, those are the only policies around the recycling of telephone numbers, and there is nothing in that document that would indicate that it addresses the digital world we now find ourselves in, and the unique circumstances that arise from within that landscape.

The future of recycling telephone numbers.

After looking over the Aging and Administration of Disconnected Telephone Numbers document, it becomes clear these guidelines are reflective of the pioneer era of telecommunications, back when cell phones were becoming a thing – but not today.  Personally, I feel any “guidelines” that have not evolved in accordance with the evolution of the telecommunications landscape, should not be passed off as guidelines, since there has not been an examination of all the grandfathered clauses.  However, that is exactly the problem we have on our hands: the guidelines around the practice of recycling telephone numbers have not been revisited in a very long time.

In order to get this right, any future review of the existing guidelines around the practice of recycling telephone numbers will need to expand to also consider a variety of factors including whether the recycling of previously suspended telephone numbers can bring about unintended privacy breaches for the past owner of the number given how interconnected numbers are with a person’s digital identity, whether the “aging intervals” for telephone numbers are still adequate for today’s digital world, and whether current industry practices provide individuals struggling with financial security enough time to get their accounts in good standing.  These aspects are important from a digital identity perspective because both the public and private sector are moving toward making telephone number verification a requirement.  Although Ontario’s Privacy Commissioner has proposed a digital identity program that might relieve telephone numbers from playing a major role in the digital world, we are probably some time away from a designated digital identification number.

Although I intend to complete a Task Identification Form regarding the matter of recycling telephone numbers, a document which is more suited for individuals that have a legal background, I also intend to submit a trickle-down ask, one that starts with the CRTC and that calls for the simplification of all forms that are associated with the general public, one of the biggest stakeholders in all of this.  The complicated nature of the Task Identification Form that the oversight bodies require to be filled out by members of the general public makes it a systemic barrier, where there is no distinction made between the general public and legal experts, and where contributions may get discarded for failing to meet the “standard” required for it to be considered valid.

This is not the end of the issue, however.  I am still waiting for some of the stakeholders to respond to my questions. Where those answers, and the implications of those answers, leave us in the grand scheme of privacy and identity in the digital age will have to be the subject for a future article.