Summary

FCS welcomes Ofcom’s proposals to tackle scam calls from abroad. Scam calls create distress and harm to members of the public.

It is important that Call Line Identifier can be trusted so that the receiving end-user can trust the number calling.

FCS has a number of concerns over the proposals, the main one being that the solution is focused on traditional mobile networks and does not sufficiently consider new technology and Over the Top (OTT) solutions. We are also concerned about the reliability of the process and the extent that the CLI can be relied upon by the called party. The process should be robust to avoid end-users being fooled into a false sense of security.

The FCS encourages Ofcom to engage more fully with OTT providers to ensure that there are not unintended consequences of the proposals, which whilst working well for MNOs may cause significant problems for OTT providers and not actually address the overriding aim of reducing scam calls.

About FCS

The Federation of Communication Services (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. Some FCS members also have some consumer customers. FCS is the largest trade organisation in the professional communications arena, representing the interests of around 350 businesses, which supply B2B services nationwide.

Although our members are not mobile operators as such  many resell mobile services as part of business solutions. An increasing number of our members purchase OTT solutions.

General comments

FCS welcomes the opportunity to respond to the consultation “Tackling scam calls from abroad” (the ‘Consultation’).

The basis of the proposal is that an international gateway will remove the CLI flag before forwarding the call to the Mobile Network Operator (MNO). The MNO will then determine if the call is roaming and if genuine the presentation flag would be restored. If the MNO is unable to verify the caller is genuine, the CLI flag remains withheld. We have some concerns that this process may not capture all mobile calls entering the UK. We believe that some calls may enter the UK via other routes such as OTT or as cloud-based services and may not have the correct identifier marking applied at the gateway. These calls could then be incorrectly presented to end-users with the scammed CLI as the call was not identified as being a scam call.

For the process to work correctly it is essential that all networks behave correctly, not just the MNO and the conventional international gateways. When bad behaviour does occur by any party in the process Ofcom will need to act swiftly to prevent harm to users. We suggest that Ofcom ensures that it has the powers and resources to take swift action and appropriate enforcement.

It is important that when a CLI is presented to a receiving end-user that they are able to trust it. If a loophole exists in the process which still allows some scam types of calls to get through it would lead end-users into a false sense of security which would cause them harm. We suggest that Ofcom investigates the proposed process to identify the scale of and fix any loopholes in the process.

Summary

We support the aim of reducing scam calls from abroad. However, we are concerned that solutions presented are based on traditional MNO architecture and do not sufficiently address the OTT landscape. We urge Ofcom to engage with OTT providers to ensure that they are not disadvantaged by the proposed solution and to ensure that the proposals address the overall aim of reducing spam calls.