Friday, December 07, 2007

COMREG Guidelines for VOIP Providers - Requirements for Directory Services

Comreg has issued guide lines for VoIP providers regarding directory services. Comreg is the Commission for Communication Regulation in Ireland.

Guidance for Service/Network providers
There are a number of steps which therefore need to be taken by market players.

Directory Services
In the first instance the service provider who assigns a telephone number to a subscriber must inform the subscriber of their right to an entry in the NDD, the different categories of records i.e. listed, unlisted or ex-directory and the functionality associated with each category.
Subscribers should be asked to signify their preference in relation to an NDD listing As the regulations define the NDD as a record of all subscribers “who have not refused to be included”, Comreg recommends that the default option should be listed” with the subscriber offered the opportunity to modify this to unlisted or ex-directory.
It is essential that in offering the choice to subscribers, sufficient information is provided to allow an informed choice to be made by the subscriber. The information and the offer should ideally be provided at the point where the subscriber enters into the contract for services. Where this has not been done for existing subscribers, ComReg recommends that this be rectified no later than end February 2008.

Having established the subscriber’s preference, the record should then be entered onto the NDD. Procedures for interacting with the NDD are specified in documentation which may be obtained by service providers from the NDD directly.

Service providers may choose to have the process of interacting with the NDD managed on their behalf by another undertaking which is willing to undertake this task. ComReg wishes to emphasize however that the statutory responsibility to ensure that the subscriber’s wishes are observed cannot be delegated to another undertaking.

Data Protection and Privacy
In addition to directory information, the standard input form for a listing requires an indication of the subscriber’s preference regarding unsolicited marketing calls. By definition, ex directory numbers have not been included as records in the NDD and service providers had no need to interact with the NDD in respect of such numbers. As the legal framework regarding unsolicited marketing calls, can only protect those numbers which are recorded in the NDD, in 2006, ComReg and the Data Protection Commissioner issued directions and notices requiring ex-directory numbers to be entered into the NDD for the purpose of including such numbers in the “opt-out register” – the listing of telephone numbers where subscribers do not consent to receiving unsolicited marketing calls.
The Direction issued by ComReg by ComReg is published as ComReg Document 07/100.

The processes for service provider interaction with the NDD are set out in a series of documents which authorised undertakings may obtain by contacting the NDD directly at this address:
NDD Manager,
Eircom Ltd.,
St. Stephen's Green West,
Dublin 2.

Additional guidance regarding communication with end-users may also be obtained through ComReg at the following e-mail address retaillconsult@comreg.ie

Released PDF file.

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