Late last year, India’s telecom regulator, the Telecom Regulatory Authority of India (Trai), issued a consultation paper proposing the mandatory display of the caller’s name on the recipient’s device, even if the name is not stored in the latter’s contact list. The idea is to empower consumers to make informed decisions while receiving calls and reduce harassment and harm from unsolicited, spam, bot, and fraudulent callers. Consumers may be able to identify the callers (by having access to their names and not just their number) before picking up the calls.
While well-intentioned, the potential positive and negative impacts of this proposal on consumers need to be thoroughly examined. For instance, there might be various scenarios wherein consumers may not wish to have their identities revealed on others’ devices. These could include calls by victims of domestic abuse, activists, journalists, auditors, investigators, watchdogs, whistleblowers, or those bound by professional secrecy.
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Also, consumers making one-off, innocuous or inquiry-related calls to e-commerce delivery personnel, cab aggregator drivers, booking agents, and other intermediaries and aggregators, may have no option but to give up their identity even before the call is picked up. This one-size fits all approach, of displaying identity of all callers, bereft of nuances, may not necessarily be an optimal solution.
Trai proposes to rely on information provided by consumers in the customer acquisition forms (CAFs) at the time of subscribing to Sim cards for the name reveal to call recipients. Concerns around reliability, safekeeping, and verification of information provided in CAFs have cropped up from time to time. It is possible that such information is not consistent with information recorded during other customer due diligence exercises. Moreover, persons filling in the CAFs might be different from the persons using the number. This may lead to revelation of wrong names.
The government is aware of these issues and has been deliberating on proposals to develop frameworks for sharing reliable know-your-customer data among telecom service providers based on customer consent. Unless some of these proposals see the light of the day, excessive reliance on unreliable CAF data may be counter-productive.
To operationalise caller name presentation, telecom service providers may need to dip into each other’s database. The sharing and passage of data through different points of interconnection between multiple networks may make data susceptible to leaks. Alternatively, the creation of a centralised database wherein details of all consumers are stored or its clones with all service providers may end up acting as honeypots for malicious actors. In such scenarios, it might be difficult to fix responsibility and hold service providers to account.
These concerns, coupled with the disclosure of personal information like name and contact number without customer consent and in the absence of an overarching data protection law could also exacerbate risks related to violation of privacy, misuse of information, and identity spoofing. Young users of telecom services may particularly be at risk in such scenarios. Consequently, it might be useful to wait for the data protection law to be operationalised before acting on Trai’s proposals.
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It is also not clear how the mere display of caller names will address the issue of fraud, spam, and bot calls. While it may give some additional information to call recipients, it may not necessarily be sufficient to distinguish genuine from other callers without picking up the call. Telecom and financial regulators in India have recently formulated a joint action plan to curb financial fraud using telecom resources. Trai has also been leveraging distributed ledger technology and artificial intelligence to curb unsolicited commercial communication. Such initiatives may have greater chances of success.
It will also be useful to examine if scarce state capacity and public resources should be invested to design regulatory intervention on an issue on which the industry is already making a lot of progress. At present, smartphone users can make use of native smartphone tools and third-party apps to identify calling party names, locations, and mark spam calls. For instance, Apple provides a ‘silence unknown numbers’ feature on its handsets. Google app allows phone users to mark incoming calls as spam and block them. Third-party apps like Truecaller and Bharat Caller ID & Anti-spam also provide calling party name presentation and spam identification facilities.
While potential exists to enhance the reliability of such crowdsourced data, the availability of additional information may aid call recipients make an informed choice about picking up the call. It might be a better idea for the regulator to join forces with these players for addressing concerns related to their solutions and generate awareness and build the capacity of consumers on using them.
Should Trai decide to go ahead with its proposal, it might be useful to think about limiting obligations of caller name display to specific categories of callers based on pre-determined principles or grievances received against callers. Similarly, options like pressing additional codes to display the caller name could be explored.
These are just some of the issues in the Trai’s consultation paper that need thorough examination from a consumer perspective. The regulator must undertake a comprehensive cost-benefit analysis of its proposals for all stakeholders before reaching a conclusion.
The writer is secretary-general, CUTS International