Tuesday 29 January 2013

Call to Comment on National Cellular Consumer Code

The CRTC has taken another step on the path to the "development of a consumer code for cell phones and other mobile devices" that I first addressed in the blog of 16 Oct 2012.


The Commission issued a number of inter-related releases on 28 Jan 2013. The lead document is an open invite to comment on a draft wireless code. A related document entitled "Proceeding to Establish a Mandatory Code for Mobile Wireless Services" contains a copy of the Wireless Code Working Document (WD) at the Appendix.

The general public can provide comment on the WD by logging in through the consultation website. (Note; I had to create a new log-in credentials even though I have other CRTC log-ins registered.) The time frame for comments is 28 Jan 2013 to 15 Feb 2013.

The WD is an extensive manuscript that is divided into numerous parts from A to F, many with multiple sub-parts. Each part addresses particular areas that were raised in the initial go around from last October. There are two columns associated with each part. Column one identifies the policy or code issue and column two provides proposed wording for the item.

In some cases, the WD provides options for the reviewer to comment on as shown in this sample:

Application of the Wireless Code to pre-paid and post-paid wireless services

Option 1: The Wireless Code applies equally to pay-as-you-go and other types of pay-in-advance services (“pre-paid services”) and to “post-paid services” (i.e. services where the consumer pays after receiving a bill).

Option 2: All sections of the Wireless Code apply to post-paid wireless services. The following sections of the Wireless Code apply to pre-paid wireless services: To be determined.

In my estimation, the WD addresses many of the concerns often expressed by users concerning their relationship with cell vendors. Will everyone be satisfied with the document or its intent? Absolutely not. is it a step in the right direction? Absolutely yes.

Further, I feel a national code is far better than a mishmash of provincial regulations that vary from province to province.

If there is a weakness in the WD, it is the lack of detailed information on how the code will be enforced. There has to be a methodology to allow for quick and effective response to consumer complaints that lead to a satisfactory or legal solution applicable to all involved within a reasonable timeframe, say 90 days. At that point, some form of sanctions needs to be available to enforce compliance.

I encourage readers to take the time to read the WD even if you do not wish to comment. Feel free to submit comments to this site if you wish.

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