For as long as I have been on the internet, I have never come across any article that focused on the importance of telephone numbers in the digital world or the privacy risks associated with the practice of recycling telephone numbers, and I believe The Voice Magazine is the first publication to bring this issue to light. The inspiration behind this three-part series, starting with “The growing importance of telephone numbers in the digital world”, came from my own experience with a recycled number, which turned out to be somewhat of a nightmare. My situation had to do with a number that Freedom Mobile had issued me back in July of 2020, a number that belonged to another person from Ottawa who had tragically passed away at the start of that year.
Shortly after getting a—supposedly new—number from my telecom provider, I started to receive calls, texts, and messages over WhatsApp and Viber from friends of the deceased man, but also from businesses. At one point, I even received calls from a representative at American Income Life Insurance Company, who I had to update on the situation, just like I had done when the person on the other line was someone who was calling on behalf of a collection agency, Walmart’s Photo Studio, and an optical clinic. This number was so connected to that person’s digital identity that I would be made aware of the previous owner when I tried to register the number with both my Airbnb and Amazon account.
The entire experience was so weird and uncomfortable, and I did end up submitting privacy complaints, but it got me thinking about the big picture implications of recycling numbers. If all of this could happen to me then it has or is happening to others too. That is why it was necessary to connect with key oversight agencies at the provincial and federal level as well as Canada’s big three telecom providers.
My questions for them seemed simple to answer, at least to me:
1) Has the practice of telephone number recycling been assessed by your organization? If so, when did this practice first come to your attention and did it result in the commissioning of any reports or studies?
2) To what extent is your organization aware of the potential privacy concerns associated with the practice of recycling telephone numbers?
3) Have the privacy implications regarding the practice of recycling telephone numbers been considered or discussed between telecom providers and Canada’s oversight agencies?
4) If it was a Canadian oversight agency, I would ask Is there any legislation that has been or is in the process of being tabled regarding the practice of recycling telephone numbers?
While I’d ask the telecom providers Are there any internal policies that are being tabled regarding the practice of recycling telephone numbers?
5) Do any members of your organization’s executive team or senior management have tech developer backgrounds? If not, can you discuss if there are any plans to bring on individuals with educational backgrounds in tech and who have hands-on experience working as tech developers?
6) Can you please speak to the long-term strategy around the practice of recycling telephone numbers given their growing importance in the digital world?
Below is how these stakeholders responded to my questions.
The Provincial Privacy Commissioners
The provincial privacy commissioners which I decided to connect with were Ontario, Quebec, British Colombia, and Alberta. These four provinces are Canada’s most populated provinces, and they account for close to 86% of Canada’s total population.
Quebec’s privacy commissioner responded by saying that they had no opinion on the matter. British Colombia’s privacy commissioner responded by stating that telecoms were not within their jurisdiction. Alberta’s privacy commissioner responded by saying that they were not in a position to speak generally about topics or issues for which other Canadian regulators have oversight responsibility. However, their responses seem questionable because each of these three privacy commissioners seemed to ignore the fact that their province also had their own version of the Personal Information Protection and Electronic Documents Act (PIPEDA), unlike Ontario.
Ontario’s privacy commissioner was the most responsive out of the four commissioners. The Ontario response started off by stating that the Office of the Privacy Commissioner of Canada had primary jurisdiction over federal work, undertakings and business, which included banks, telecom providers, and airlines, since they were subject to the PIPEDA. They also stated that Ontario only provided oversight for provincial access and privacy laws that applied to Ontario institutions as well as child and family service providers, and that commercial activities were under a different jurisdiction, and that they relied entirely on federal legislation regarding privacy matters.
What Ontario did have going for it, however, was that the Privacy Commissioner’s 2021 Annual Report correctly identified that our privacy laws were enacted long before anyone could have imagined a digital world and it also highlighted public policy gaps, with recommendations for a Digital Identity Program.
Federal Privacy Commissioner
The Federal privacy commissioner was the most direct out of everyone. They confirmed that they did have technical experts on staff, a Technology Analysis Directorate, who was responsible for analyzing technological trends and developments, conducting research to assess the impact of technology on the protection of personal information in the digital world, and providing strategic analysis and guidance on complex, varied, and sensitive technological issues involving government and commercial systems that store personal information.
However, they also stated that they had not examined industry practices related to the practice of recycling telephone numbers but did go over aspects of Canada’s federal private sector privacy law, the PIPEDA, which set the ground rules for the handling of personal information in course of commercial activities and recommended that I connect with the CRTC on those matters.
Canadian Radio-Television and Telecommunication Commission
The Canadian Radio-Television and Telecommunication Commission’s (CRTC) response came closer to the deadline for this article, and after I had already connected with Privacy Commissioners and the CRTC’s subsidiaries. They informed me that their privacy team had looked over my questions and they were recommending that I connect with the Privacy Commissioner and the Canadian Numbering Administrator, but they did not answer any of the questions that were formally submitted to them over their request portal.
Canada’s big three telecommunications providers
Canada’s big three telecommunications providers might be viewed as equivalent giants, but their responses to my questions were anything but that. Out of the three, Rogers was the only giant I did not have to chase for a response, and they responded within 24 hours, while the other two giants put little thought into their responses.
Rogers introduced me to the Canadian Numbering Administrator and recommended to connect with them regarding these matters, because they were accountable for following guidelines set in place by the CRTC and its subsidiaries. They were the most helpful, and I felt that I was dealing with individuals who had a strong understanding of the telecom industry.
Bell’s privacy expert was away from work when I first contacted them, but the response they provided upon returning to work made it clear that they put little effort into understanding my questions. They responded by saying that their customers’ privacy has always been a top priority and that they complied with the privacy laws, but that numbers were a finite resource and not owned by customers. They also stated how numbers, “are only recycled when not in use after an appropriate period and customers are able to port their numbers to another service provider if they wish to.” Although I appreciated that Bell took the time to respond, waiting to hear back from their PR team after they had said that their privacy expert was away from work, their response was a big miss. It felt like a cut and paste statement, with little thought for the issue.
Unlike Rogers and Bell, my call with Telus’ PR lead abruptly dropped only 5 seconds into our conversation, and after their head office’s reception desk transferred my call. My attempts to follow up with Telus’ reception desk and PR team went unanswered right up until the deadline for this article to get published. When they did respond, their response was so far off, recommending that I connect with the Canadian Wireless Telecommunications Association, who represented wireless manufacturers and carriers and who had no connection to the privacy issues I was inquiring about.
Most of what I was hearing from Canadian stakeholders seemed to indicate that their executive teams had a singular skillset and that there was a limited understanding of the potential privacy implications related to the practice of recycling telephone numbers. Obtaining a recycled number from a telecom provider has nothing to do with cybersecurity and everything to do with potentially having access to another person’s entire digital history across various digital platforms, similar to what transpired after I received a recycled number from Freedom Mobile—but they seemed to be unable to grasp the gist of the challenge.
It was concerning enough that I decided to reach out to the North American Numbering Plan Administrator, and I would be following up with other international stakeholders. My conversations with these and other international stakeholders leads me to believe that the practice of recycling telephone numbers is going to start being a major topic of conversation among numbering authorities around the globe.
No country for old men or women
As the digital era commences, the generational challenges between young and old, the traditional approaches towards legislating, and other outcomes, they are all bound to clash, as is the case with the practice of recycling telephone numbers. Although there may be some Canadians that have a nostalgia for the days of our past, sticking to tradition—also a synonym for obsolete policies and protocols—needs to be balanced with the needs of the present and for the future. Additionally, Canada is in big trouble if people in positions of consequence refuse to act, using jurisdictional boundaries as an excuse: a total diffusion of responsibilities and a sociopsychological phenomenon that has created chaos throughout history. However, past excuses are no longer acceptable in the present, and they will keep us from arriving at the future we all deserve if we allow them to persist.