With any new industry, the focus of the early builders is – quite naturally – building. When they put railroads across America, not much (if any) concern was given to the employment rights of ticket collectors. When consumer access to the Internet was emerging, ISPs didn’t obsess about blocking illegal content. In fact, as the second example might illustrate, the new is freedom from the old and that is quite often seen as good. We see the same in Bitcoin now – money which can’t be censored and where you can’t be de-banked. But, as any industry reaches maturity and becomes the new normal, society’s agreed acceptable ‘norms’ need to be applied. Not everyone recognises or wants that and it causes tension.
Look at VoIP today. 20 years ago, it might have been acceptable to pop a sticker on a handset saying “999 not supported”; today it isn’t, although some of us would argue it never was because VoIP was always better than what it replaced. It might have been acceptable for quality to be inferior because it was cheap; today it isn’t and it is rightly claiming its ever-rightful place as better than what it replaced. However, even today in 2025, there are operators who still think it is 2005. Maybe they just haven’t evolved and are still dining out on yester-year – we see plenty of those. Maybe they still have that pioneer spirit and don’t agree with the ‘norms’ they thought they’d escaped – we see a few of those. Or maybe they just cannot be arsed and consider the normalisation of their business an intrusion that has to be resisted, with William Wallace’s cries of freedom echoing round their head as they shake it at Ofcom’s latest dictat.
Don’t get me wrong, I’m no fan of rules and this certainty isn’t going to turn into a defence of the Online Safety Act – an abhorrent piece of self-sabotaging, naive nonsense which, like most things the Government touches, will make things worse. No, this is about our industry and its professionalisation. I hold our customers to a higher standard than other carriers – in intelligence, capability and caring for the end user. We have actively terminated customers who demonstrate incompatible values – regardless of size – and that assumes they somehow managed to get past our KYC in the first place, which only a small proportion do. A Carrier Services account with Simwood is not a commodity; it is recognition that you’re the best of the best. However, rather like Top Gun, you may be the best of the best, but we want to make you better, because our industry and consumers deserve it.
Flattery out the way, let me now moan about nuisance calls! I am increasingly of the opinion that some of you out there have convinced yourselves that us spending a tonne of money, to reject revenue and then burn costs arguing with you about why, is simply us being difficult. That wouldn’t be sensible or rational, but your inner William Wallace disagrees. We’re blocking more nuisance calls than anyone else (prove me wrong!), and that is both calls incoming to your customers and calls outgoing from your customers. We’ve had no support tickets about the grannies on your service whose life savings have been preserved – understandable as neither they nor you know what we’ve blocked. We do get tickets, though, where we’ve blocked one of your customers and you disagree, cynically perhaps, because they spend lots of money with you.
Recent examples include where 40% of the calls were to numbers not in service, a taxi company where literally 0% of calls ever connect, and a data polling application where only 3% of the calls ever connect. It has been put to us that blocking these is somehow inappropriate because <insert some virtuous reason where the calling party is a decent chap>. I disagree, and it is important that we get to a place where you do too.
I think we’re all on the same page with regards to genuine “nuisance” and “scams” and, with a few exceptions whose business model runs close to the line and want to know where exactly the line is, agree they’re bad and should be blocked. If we look at these edge cases, that is where the virtue comes in – none of the above examples are scams or nuisance calls once you know that the caller is a decent chap and doing “nothing wrong”. Or are they? Let’s consider other perspectives.
If someone has 40% of their calls to numbers which are not in service, that doesn’t smack of natural traffic to consenting recipients to me. It rather feels like robotic war-dialling, very very bad data, and an absence of the checks the law requires them to be making before making commercial calls (TPS etc.). Auto-dialled calls require express consent, amongst other things, and how can consent ever be given on a number which is not in service?
Next, zero calls connecting. This one is tenuous, given the calls could be originating in a call centre, with an obligation to make 0% silent calls, but the recipient might welcome knowing the taxi is there without having or wanting an opportunity to answer. You could argue it either way and until tested by regulatory enforcement, it’ll be ambiguous. Rather, if we assume the calls are lawful and the recipient welcomes them, who is paying for those calls? Our industry operates on revenue following answered calls. Where there are no answered calls, our network, and that of the downstream network is being used and incurring costs, with zero revenue. We need to maintain cordial relationships with our downstream networks, most of whom are the direct terminating network, and sending them 100% cost traffic is not welcome. As a transit network, if our capacity to the first choice destination is more full than it otherwise would be due to crap, it means quality traffic from other customers risks over-flowing to secondary (less direct and more expensive) routes. Maybe it isn’t illegal, but it is a nuisance that nobody wants.
That links us nicely into the last example, where only 3% of calls connect. By any measure this is spam traffic until you know the application and the fact that the same numbers are being repeatedly redialled until they have a mobile signal. Again, this is abusive of all the networks in the chain as when you look at the stats, 1m minutes of revenue would involve 167m call attempts, each consuming resources and costing money. That is bad business for anyone, except the caller, whose costs are paid by everyone else. This is legally nuanced again, thoug,h as while neither the caller and the recipient might not be human, they are being dialled automatically and there is a clearly a “persistent misuse” element at play.
Where call recipients are harmed or the very clear rules on commercial or automatic calling are breached, the ICO can fine up to £500k, Ofcom can fine up to £2m for persistent misuse causing harm, and the Data (Use and Access) Act 2025 (DUAA) lifts potential fines to 4% of global turnover or £17.5m. Admittedly, those are generally fines on the caller but you have a duty of care, and I might argue, risk facilitating them.
When it comes to costs on our and downstream networks, we’re changing how we handle both channel limits and call rate limits. Opening our network up to take the strain seems to be sending the wrong signals and from now on those operators who decide to carry this bad, undesirable or at best nuanced traffic will face constraints to avoid disadvantaging others. The more undesirable the traffic, the less of it will get through. The better the traffic, the more open we’ll be. Pete blogged about this separately earlier. We hope this will focus minds that capacity isn’t infinite and cost-free and is better used for your premium traffic.
If our stance on this is problematic, regrettably, there are plenty of other networks who offer “Sewer as a Service”, and some of them work all week. We’d much prefer though that our awesome customers see this traffic for what it is and focus instead on adding value for high quality customers.
Also, this is the final call for our nuisance calling webinar. If you want to understand what we’re doing with nuisance calling and why, please put your name down – invitations going out soon.
