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Telecom - Staff Letter addressed to Jean-François Dumoulin (Iristel Inc.)

Ottawa, 13 December 2024

Our reference: 8000-C12-202306414

BY EMAIL

Jean-François Dumoulin
Vice President Regulatory and Government Affairs
Iristel Inc.
403-16766 TransCanada Hwy
Kirkland QC H9H 4M7
regulatory@sugarmobile.ca

Subject:  Provision of Local Service Provider Identification

In Telecom Decision CRTC 2022-238, the Commission took certain regulatory measures to protect customer information. This included determining that unless a customer provides express consentFootnote 1 or disclosure is pursuant to a legal power, all information kept by a telecommunications service provider (TSP) regarding the customer, other than the customer’s name, address, and listed telephone number, including but not limited to IP addresses and unlisted mobile wireless telephone numbers, is confidential and may not be disclosed by the company to anyone other than:

  1. the customer;
  2. a person who, in the reasonable judgment of the company, is seeking the information as an agent of the customer;
  3. another telephone company, provided the information is required for the efficient and cost-effective provision of telephone service and disclosure is made on a confidential basis with the information to be used only for that purpose;
  4. a company involved in supplying the customer with telephone or telephone directory-related services, provided the information is required for that purpose and disclosure is made on a confidential basis with the information to be used only for that purpose;
  5. an agent retained by the company in the collection of the customer’s account, provided the information is required for and is to be used only for that purpose;
  6. a public authority or agent of a public authority, for emergency public alerting purposes, if the public authority has determined that there is an imminent or unfolding danger that threatens the life, health, or security of an individual and that the danger could be avoided or minimized by disclosure of information; or
  7. an affiliate involved in supplying the customer with telecommunications and/or broadcasting services, provided the information is required for that purpose and disclosure is made on a confidential basis with the information to be used only for that purpose.

In that same decision, the Commission acknowledged that it had previously approved certain TSP-specific exemptions, such as in relation to Local Service Provider Identification (LSPID) services provided by Bell Canada and TELUS Communications Inc.Footnote 2 (TCI) in support of Canadian Law Enforcement Agencies (LEAs), and that such exemptions continue to apply.

Commission staff understands that Iristel may be disclosing LSPID or similar information to LEAs and other individuals or organizations.

While there are situations in which TSPs may be requested to provide customer information, such as during the course of an LEA investigation, Commissions staff wishes to better understand whether and in what circumstances Iristel may be sharing customer information.

Consequently, Iristel, by 10 January 2025,Footnote 3 is requested to confirm whether it has provided or provides LSPID or similar information to any third party. If so, Iristel is to:

  1. Provide details on the process through which Iristel receives and fulfills requests for this information, including what information must be provided by organizations seeking this information; the criteria, if any, that Iristel applies to accept or deny a request; and what fee(s) Iristel charges for providing this service.
  2. Provide the name and type (e.g., TSP, LEA, etc.) of all organizations that have requested this service from Iristel; the number, nature and date of the requests placed by each organization; and a confirmation of whether Iristel fulfilled each individual request.
  3. Indicate whether Iristel considers the provision of this information to be equivalent or comparable to LSPID service, such as that provided under tariff by Bell Canada and TCI.
    1. If yes, identify the Commission decisions, policies, and/or orders that Iristel believes authorize it to provide such a service.
    2. If not, explain how Iristel’s actions and service(s) differ from an LSPID Service, and in accordance with what Commission determinations is Iristel acting.
  4. Indicate whether Iristel advertises or takes other actions to make Canadian organizations aware that it is able and willing to provide this information? If so, provide details, including any online links or resources or promotional material of this service on Iristel’s website or elsewhere.
  5. Provide any additional relevant details that could contribute to the Commission’s understanding of this matter.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Iristel may designate certain information as confidential, though it must provide a detailed explanation on why the designated information is confidential, and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, should Iristel designate information as confidential, it must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementations
Telecommunications

c.c.:  Etienne Robelin, CRTC, etienne.robelin@crtc.gc.ca

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