We’re changing our MSA to be more permissive and explicit with regards to a quirk of the (fundamentally broken) industry porting process we know as “wholesale ports”.
Background
Where we are supplying wholesale services, the porting process exists for the benefit of the end users and our porting agreements are there to enable your customers to move from you to another communications provider if they wish, rather than for you (our wholesale customer) to move numbers elsewhere. We have always prohibited wholesale ports, as do all competitors with processes robust enough to spot them.
We process broadly 100 times as many porting orders in to our network as out, which suggests our wholesale customers are doing things right. However, the definition of a “wholesale port” remains somewhat vague and open to interpretation. There is not, and never has been, any restriction on us processing a port request to enable your customers to leave your service (and us by consequence); that scenario, and the reverse, is what the porting process exists for.
Problem
When we observe wholesale port attempts, things generally don’t end on a positive note. Most of the time those who try don’t take kindly to being told they can’t and what follows is something between disagreement and a recasting of reality. Some are able to produce signed Letters of Authority, often accidentally signed on behalf of the end-user, whilst others freely admit to misrepresenting themselves as a wholesale customer and claim to be the end-user for all numbers on their wholesale account.
A competently regulated process would deal with these issues, or render them moot by handling wholesale porting (as we asked and would prefer) but that is a pipe dream at present. Instead, we need to handle it in a way that gives maximum clarity for our customers, ensures your end users can legitimately exercise the right they’re entitled to, whilst we’re not opening our business up to abuse in terms of additional processing costs, unfairly lost revenue and ongoing capacity usage and costs (numbers ported out use double the capacity of on-net numbers).
Solution
Our solution is to relax our efforts to identify wholesale ports, and to allow a base level of porting on an account to represent natural end-user churn. Beyond this, we will be charging for attempts to export numbers without any discussion over whether they are wholesale port attempts or not. This protects end-users, enables our customers to handle the very exceptional legitimate cause for abuse of the process, whilst protecting us against a concerted effort to abuse the porting process to our detriment. The charges applicable are published in our non-call pricing sheet (also linked from our main rates page).
The new policy is outlined in our AUP, and we’re re-affirming this by way of a change to our Master Services Agreement to which all customers subscribe by continuing to use our services, which will formally reference our Number Portability Policy distinct from the AUP. This blog is an explanation and heads-up so nobody feels this has been hidden, but customers will be more formally notified and as usual the MSA will be referenced from the login page to the portal.
Conclusion
This change will not affect most customers, and even those customers who do see exports of numbers should find it more permissive than previously. We hope we’ve got the balance right but naturally would welcome your feedback.
