Whilst the implementation of the new CLI policies around General Conditions 6 has largely gone without incident, we’ve experienced a number of reports of called parties wrongly seeing the Network Number, and the CPs concerned aren’t acting swiftly to resolve it.
We fully support Ofcom’s aims here, however we cannot – nor can we allow our customers to be – in a situation where they are disadvantaged commercially just for following the rules so are relaxing our stance in a couple of situations;
International Calls
Whilst the UK regulations are clear and it is unambiguous that all CPs should be presenting only the Presentation Number to the called party, other countries have less stringent policies and some don’t even support the concept of a Presentation Number. As a result, some international calls have been delivered with the Network Number being erroneously provided to the end user.
Therefore, where we have a local presence in a country (or via partners that do), and we can keep the call entirely off the PSTN in the UK, we will set the Network Number for the call to the number you provide in the P-Asserted-Identity header, even where this isn’t a number on your account.
Interconnect Services
We recognise that our Virtual Interconnect and Managed Interconnect customers operate their own networks, and use us as a gateway to the PSTN alongside other providers. Here, we aim to be as transparent and unobtrusive as possible and allow you to operate your own network and let us handle the awkward integration with the PSTN.
We’re aware that a large number of you operate call forwarding services to add value-added services along the way and these calls enter your network from another route, with a Network Number present.
General Condition 6 provides that calls transiting a network should be passed unchanged, and our current policy precludes this as a Network Number may be overwritten. It also seems that some of the rules are open to interpretation.
Delegation of GC6 Responsibility
With this in mind, from later this week (we’re just having the legal experts cross the t’s and dot the i’s), we will be offering an Addendum to the MSA for Virtual Interconnect and Managed Interconnect customers that meet the description of being a PECN that will delegate GC6 Compliance clearly to the customer.
This will enable eligible customers to pass a Network Number on a call that is not a number on their account i.e. where the call entered their network with a Network Number already present and the call is being forwarded, or where this is their own number but hosted with another operator.
It’s worth noting that, in our opinion, except where a call is transiting your network having been originated elsewhere, the Network Number should never be a number you don’t control, but ultimately as a network operator that’s your call to make and one we won’t interfere with.
Customers taking advantage of this should keep in mind the risk that in future CPs aiming to comply with the inbound elements of the new General Condition 6 may potentially block calls with incorrect network numbers if they can confidently determine it’s not one you should be presenting.
If you’d like more information on this, then contact your account manager. If you’ve already got a ticket with us about any aspect of GC6, we’ll be in touch to offer you this solution.
