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									                                                                         CLI-IG CP (00) 004

                        CLI INTEREST GROUP

                       Draft Minutes of Sixth Meeting
                             24 February 2000
                      50 Ludgate Hill, London EC4M 7JJ
Apologies (item 1)
1.    Apologies and those present are listed in the Annex attached.

Minutes of fifth meeting (item 2)
2.     The action points (doc 99/003) arising from the fifth meeting held on 12 April 1999
were reviewed. It was noted that drafting of a Service Provider Code of Practice had now
begun and that BT would be making CLI available on Featurenet within this calendar year.

OFTEL Statement on Presentation Numbers (item 3)
3.     Frank Phillips introduced the OFTEL Statement Presentation numbers - the
development of calling line identification services in the UK which had been published a
week before the meeting. The Group was already well acquainted with the original
Consultation and there were few surprises in the Statement.

4.     However attention was drawn to the active involvement of OFTEL in determining
which applicants should be allowed to use type 3 presentation numbers for an initial period of
eighteen months or so, pending a review. OFTEL had taken this step reluctantly but in
response to two separate concerns: that of consumer groups who felt that the authenticity of
CLI information could be compromised unless OFTEL took an active policing role and that
of operators who felt that they were not qualified to make quasi-regulatory decisions about
which of their subscribers should be allowed to use type 3 numbers. Moira Black added that
consumers do not trust self-regulation.

5.      Paragraph 3.4 of the Statement envisaged a role for the CLI Interest Group in drawing
up detailed procedures for processing applications and what the precise roles of operators and
OFTEL should be in the process. This would be more suitably handled by a small working
group - amongst others BT, BT Cellnet, Cable & Wireless and Telewest offered to
participate.

6.     In response to a question from Roland Perry about the use of a presentation number to
authenticate billing, in the context of an individual accessing a service from a number of
separate NTPs, Peter Walker explained that this should be based on network rather than
presentation numbers. Peter Clarke made the point that the essential purpose of presentation
numbers was to be able to return calls.

7.     Alan Houldsworth (Siemens) said that his company had CPE capable of inserting type
3 presentation numbers and would be offering services to its customers.
8.     Richard Cox thought the indicative questions in Annex C of the Statement were
incomplete and did not cover the situation where a system was set up erroneously.
Suggestions were invited for how Annex C might be improved. John Hennock (ASAP)
thought that the Statement had failed to meet the particular needs of social and community
alarm providers. Any issues here will be dealt with outside the meeting.

9.      After some discussion it was concluded that the technical study of the feasibility of
indicating the status of CLI information by text message or spoken network announcement
mentioned in paragraph 3.9 of the Statement was more appropriate for the Network
Interoperability Consultative Committee (NICC). Moira Black thought that pressure should
be applied on NICC to respond quickly; Rob Borthwick (Vodafone) that it would be better to
wait to see if there was a problem.

                 AP 6/1 - CLI -IG secretary to convene procedural group

Service Provider CLI Code of Practice (item 4)
10.     Peter Walker introduced this item by reminding the meeting that network operators
enjoyed the capability of accessing withheld network numbers. Nowhere in the TDPD is there
any provision limiting this facility to network operators. On the principle that there should be
no discrimination between network operators and service providers, SPs acting as transit
carriers should be placed on the same footing. However equal rights of access need to be
balanced by an equivalent to the Network Code of Practice (CoP) which would apply the
Directive's privacy requirements. There is a solution to the technical problem as NICC had
already specified an appropriate interface.

11.     Roland Perry, Regulatory Officer of the London Internet Exchange (LINX), who is
drafting the CoP, introduced himself. The push for the CoP was coming from ISPs but he was
speaking to other Service Providers to become aware of their requirements. There were a
number of Data Protection issues still to be resolved; as an example, there was no clarity over
the point of termination of a call.

12.      Peter Walker commented that the problem of where the NTP is should be analysed
under Data Protection rules. European Data Protection legislation prohibits the transfer of
personal data beyond EU boundaries other than to countries that ensure an adequate level of
protection. He also noted that Short Message Service (SMS), which does not offer CLI
restriction, and other data services were conventionally viewed as falling outside the scope of
the TDPD.

13.    Other points made were that airtime providers and Calls & Access providers would
not come within the Service Provider CoP and that there was no immediate intention of
merging the new CoP with the existing Network Operator CoP although this could be
considered in future.

14.    The Service Provider CoP would be presented to the CLI Interest Group for
endorsement, ideally within the next two months.

Amendments to Network Operator CLI Code of Practice (item 5)
15.   Frank Phillips introduced a document (doc 00/002) proposing amendments to the
Network CoP. The most significant change, at the behest of the Data Protection
Commissioner, is to tighten up paragraph 2.5 which deals with operator access to withheld
CLI. A revised version of the paragraph was put forward, making it even clearer that withheld
CLI should only be used in circumstances where its use is essential to the provision of a
telecoms service and adding the new restriction that access to withheld CLI within an
organisation should be limited to those members of staff for whom access to such information
is vital in order to provide a telecoms service.

16.     Less significant changes redefine network operators as operators with Annex II status
under the Interconnection Directive, lift the requirement that presentation and network
numbers should be allocated to the same legal entity, and seek to redefine premium rate
service numbers by reference to the Numbering Conventions rather than the ICSTIS list.

17.     Comments were invited on the amendments which will be endorsed by the next
Interest Group meeting

           AP 6/2 : all members to comment on the proposed CoP amendments

Implementation of Directive 97/66/EC (item 6)
18.     The Regulations implementing the TDPD enter into force on 1 March. A paper (doc
00/003) was circulated with relevant extracts from the Regulations pertaining to CLI . Frank
Phillips highlighted Regulation 15, which requires telecoms service providers who offer
Calling and Connected Line Identification to take all reasonable steps to publicise the fact and
the effect of the new Regulations. The Data Protection Commissioner thought that this would
require a new round of publicity from operators notwithstanding CLI services have been
available since 1994. Elsewhere the Commission had made it clear that bill-stuffers would be
sufficient - not that every subscriber needed to acknowledge receipt on an individual basis.

19.     The mechanics of this exercise would be discussed between OFTEL and the Data
Protection Commissioner.

           AP 6/3 : OFTEL/DPC to consider implementation of regulation 15

Cross-border CLI - the ETP Guidelines (item 7)
20.    The progress of the European Telecommunications Platform (ETP) Guidelines on CLI
was noted. The ETP had now produced a draft Version 2 which accommodated most of the
comments made by regulators through TRIS, an ECTRA working group. There had been a
successful joint meeting of TRIS members and the ETP CLI working group.

21.     The next step is for the Guidelines to be accorded a degree of official recognition,
such as endorsements by ECTRA, the Commission's Article 29 Committee, the Independent
Regulators Group (IRG) and individual National Regulatory and Data Protection authorities.
The Guidelines, which present a best practice approach, can be referenced in cross-border
interconnection agreements between operators, providing the basis for a consistent approach
to the handling of privacy and data protection issues arising from the export of CLI
information.

22.    This will help to overcome the tension between the Revised Voice Telephony
Directive obligations on member states to remove any regulatory restriction to the
Community-wide availability of CLI services and the restrictions imposed by Data Protection
legislation which currently requires UK operators to strip out CLI information on outgoing
international calls because they cannot guarantee that their customers' data protection rights
will be respected by terminating operators.

23.. Because Version 2 of the Guidelines are still in draft it was not possible to make them
available to the Group. However they will be circulated once a definitive version is ready.

                  AP 6/4 - CLI-IG secretary to circulate ETP Guidelines

Current CLI issues: (item 8)
24.     OFTEL has received a small number of complaints about calls connected through
operator services being able to circumvent ACR. At the time of connection common practice
appears to be that the operator does not know whether the calling party has withheld CLI or
the called party invoked ACR. The consensus of the group seemed to be that the position
should be monitored and reassessed once ACR has been widely available for a longer period.

25.    Peter Walker raised the question of operators with systems that did not convey CLI
information. This was fundamentally unacceptable for a number of reasons, not least the
concerns of law enforcement agencies, and OFTEL would be considering whether to use its
powers to mandate technical requirements under the Interconnection Directive.

26.      Moira Black (CCE) said that "unavailable" was vital for helpline services which might
wish to return calls to vulnerable persons without having to disclose their identity and place
their clients at risk. Peter Walker acknowledged that where there were "life and death"
problems solutions could be found.

Any other business (item 9)
27.   There was none.

Date of next meeting (item 10)
28.    In order to amend the existing Code of Practice and endorse the Service Provider
Code of Practice the next meeting will be held within the next three months.


Fp.29/02/00
[climin06.doc]
ANNEX A

Present:

ACC                          Pritam Dhanjal
ASAP                         John Hennock
BBC                          Chris Bell
BT                           Alan Presland
BT                           John Bussey
BT Cellnet                   Ian Roy
CCE                          Moira Black
CWC                          Peter Clarke
LINX                         Roland Perry
Mandarin Technology          Richard Cox
Marconi Communications       Ian Spiers
Nortel Networks              Mark Watson
OFTEL                        Peter Walker (Chair)
OFTEL                        Frank Phillips (Sec)
OFTEL                        Phil Cobb
Orange                       William McCoubrey
Siemens                      Alan Houldsworth
Telewest Communications      Rob Templeton
Telewest Communications      Sara-Jane Amey
Vodafone                     Rob Borthwick
Vodafone                     Simon Sporton

Apologies

British Gas                  Richard Wallis
Call Handling Services Ltd   Len Ross
CCTA                         Alan Bennett
CWC                          Neil Callan
DPR                          Lorraine Godkin
Global One                   David Norton
GTS Europe                   Christophe Pham
Siemens                      Mike Norman
Standard Life                Brian Barbour
TMA                          Michael Dixon
                             Anthony Naggs

								
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