Madam Chair, good afternoon. I'm Howard Slawner, vice-president, regulatory telecom at Rogers Communications. I am joined here today by my colleague Deborah Evans, Rogers' chief privacy officer. We appreciate this opportunity to appear before the committee and to provide input into the study of fraud calls in Canada.
Rogers fully supports the efforts of the Government of Canada and the CRTC to address the problem of nuisance and fraudulent calls. At best, these calls interrupt the peace and privacy of Canadians. At worst, they constitute crimes, often preying on the most vulnerable. Together these calls undermine the integrity of our national telecom system.
The unsolicited telecommunications rules, including the requirement to register with the national do-not-call list operator, have become well-established practices within the legitimate Canadian telemarketing community. In the 10 years that have passed since the introduction of the national DNCL, over 18,000 telemarketers and their clients have registered with the operator, respecting the privacy of the more than 13 million Canadian telephone numbers that have been enrolled.
There is, however, an important distinction between nuisance calls and fraudulent calls. Many nuisance calls are placed by legitimate parties, including not-for-profit and commercial organizations. While we can appreciate the frustration of Canadian consumers resulting from some of these types of calls, it's the growth in fraudulent calls that drives most concerns today.
The parties placing spam, fraudulent and blatantly spoof calls are aggressive and unrelenting, despite the established rules in place to protect consumers. Since they operate without fear of retribution or sanction, the mere existence of a national do-not-call list will not be sufficient to eliminate the issue. That is why Rogers, like its peers, is doing its utmost to eliminate these types of calls from our network. In fact, Rogers is diligently working to rid our network of all forms of unwanted mass calling. Over the last five years, Rogers has taken a leadership role in the industry, helping to spearhead several initiatives to tackle the problem.
Since 2015 we have worked with the CRTC enforcement branch to provide network resources, including telephone numbers and call routing, for the Canadian telephony honeypot project. This initiative collects data about fraudulent calls targeting Canadians in order to identify the methods used and assist with enforcement. For the last four years Rogers has also actively participated in the CRTC Interconnection Steering Committee, CISC, to review call blocking, STIR/SHAKEN and call traceback solutions. Rogers has taken a leadership role in many of these processes, including co-chairing several of these CISC working groups.
In 2017 and 2018, Rogers also took the lead in exploring and scoping an industry-wide filtering solution to reduce unwanted calls. Over 18 months, Rogers led a committee of 12 major carriers to assess various options. This culminated in an RFP to find a national analytics engine database, as well as a Rogers-specific RFP to potentially upgrade our network.
Finally, in 2019 Rogers worked with other Canadian telecom service providers to develop and deploy universal call blocking at the network level.
More recently, Rogers started to deploy STIR/SHAKEN. This technology will authenticate caller ID and is expected to be network ready by the end of 2020. Rogers has led many cross-industry committees to establish the best practices and mechanisms that will support its deployment, including the creation of the Canadian Secure Token Governance Authority to manage STIR/SHAKEN operations in Canada. In fact, we funded the initial work of the CSTGA.
Unfortunately, these solutions are time-consuming and complex to deploy. Telecom networks are designed to permit call completion, not prevent it, and blocking illegitimate traffic without interfering with legitimate calls is harder still. For example, while the telecom industry is working very hard on delivering STIR/SHAKEN this year, it still remains far from being launched on a commercial basis. Some standards remain to be defined, including how to display STIR/SHAKEN on the end-user devices. STIR/SHAKEN also requires end-to-end IP interconnection, which is a long time away.
Moreover, even as the industry adopts increasingly more countermeasures, the criminals are not resting. Their tactics and techniques continually evolve and change so that stopping unwanted mass calling becomes even more difficult. Most importantly, they are almost all situated offshore.
There is, however, much that can be done to combat unwanted mass calls. It will require the co-operation of industry, the CRTC and the Government of Canada.
First, the telecom industry must continue its current work instituting universal call blocking and STIR/SHAKEN. While these efforts will not end nuisance and fraudulent calls on their own and they will take time to fully implement, they do provide a foundation upon which other efforts can be based.
Second, the industry must continue to develop new methods of targeting these types of calls. Unwanted mass calling is an arms race, with each side continuously upgrading their efforts. New technologies and processes are being developed each year, and carriers must be quick to adapt and adopt.
Third, the CRTC should expand its enforcement of the rules. As the primary regulator of the telephone system, the commission must ensure that bad actors are punished. Since carriers are prohibited under the Telecommunications Act from simply blocking calls, the CRTC must be proactive in shutting down fraudulent calls when observed.
Fourth, the commission should target the points of entry in malicious calls. A large portion of international nuisance calls are coming into Canada through a small number of points of entry. The commission should therefore focus its efforts on why and how such calls appear to be entering Canada in this manner and what can be done to prevent it. It could emulate, for example, the efforts by the FCC, the U.S. Department of Justice and the Federal Trade Commission, which have recently worked together to stop incoming international robocalls at domestic telephony traffic gateways, that is, specific entry points into the United States.
Fifth, the CRTC can accelerate the deployment of SIP trunks. SIP interconnections allow carriers to adapt better technologies that can combat malicious calls, STIR/SHAKEN in particular. SIP, however, is not mandated at this time, and some carriers are deploying it sooner than others. The commission should be pressing for its widespread adoption.
Sixth, the Government of Canada itself has a crucial role. The overwhelming majority of nuisance and fraudulent calls originate abroad. The government, through Global Affairs Canada and the RCMP, must work with its foreign counterparts to shut down the call centres and robocall platforms that originate these fraudulent and spam calls. As long as these parties continue to operate with impunity, they will simply find new and alternative ways to circumvent the protections and measures implemented by telecom service providers to defeat this problem. There is no better way to stop these calls than at their source.
Last, there is an important educational component. Every stakeholder can help Canadians become more aware of how to avoid the scams that are driving these fraudulent calls. Rogers has resource materials available on our website to help consumers spot a telemarketing scam, how to protect themselves from caller ID spoofing and spam calls and how universal call blocking helps protect them.
At the same time, organizations such as the Canadian Anti-Fraud Centre are active in educating consumers about frauds, including those that abuse the telephone system, and in improving awareness of the techniques employed by the fraudsters, but they, along with all of us, should do more on this aspect, especially with vulnerable people and immigrants.
Rogers looks forward to working with its peers, the CRTC and the government to address this critical issue for Canadians. Thank you for the opportunity to participate in this review. We are happy to answer any questions you may have.