Dear BIST Security team,

Please find below the FCS’s response to BIST’s consultation on the proposed updates to the Telecommunications Security Code of Practice 2022 (CoP). Our response is not confidential.

The FCS represents companies which provide professional communications solutions to business users. Our members deliver telecommunications services via mobile and fixed line telephony networks, broadband, satellite, wi-fi and business radio. Our members’ customers range from SMEs, home-workers and micro-businesses up to the very largest private enterprises and public sector users. FCS is the largest trade organisation in the professional communications arena, representing the interests of circa 350 businesses which supply B2B services nationwide.

As our members are in the main, small CPs and resellers, they are not subject to the Telecommunications Security CoP and so we haven’t answered individual questions, but we do have a couple of overall points to make.

The FCS welcomes the review of the CoP and agrees that telecommunications security is a key area for the whole communications industry.  Connectivity is central to the health of the UK economy and affects every area of society. It is important that there is up-todate guidance for the industry that reflects changes to technology and usage.  The Government, with its insight to current threat levels, is uniquely placed to provide leadership in this area and it is good to see BIST working with industry experts to update the CoP.  The changes suggested appear to provide welcome clarification.

Whilst the CoP is aimed at larger network providers, appropriate security is crucial throughout the telecommunications industry, and it is important that learning is disseminated throughout the supply chain.  This is particularly the case in relatively new areas, such as e-Sims and APIs and the FCS urges BIST to consider how best to get messages to a wider audience.  The FCS would be very happy to work with BIST to do this and provide insight into the complex supply chain if this is helpful. 

Please let me know if you would like to discuss our response. 

Many thanks,

Stefanie Norman

Head of Regulation and Public Affairs

For the Federation of Communication Services