Industry body COAI has contended that implementation of Calling Name Presentation (CNAP) should not be made mandatory but kept optional for telecom operators, as the association shared technical, privacy and cost related concerns with regulator TRAI to argue its point.
The submissions came as part of a consultation process initiated by Telecom Regulatory Authority of India (TRAI) on the need to introduce the Calling Name Presentation (CNAP) supplementary service in the telecommunication networks.
Put simply, CNAP is a supplementary service which enables the caller's name to flash on phone screens when someone calls.
COAI, whose members include Reliance Jio, Bharti Airtel and Vodafone Idea, said "CNAP should not be mandatory and should be optional for the telecom service providers".
"Implementation of CNAP should be left to TSPs and they may consider implementing the same keeping the market dynamics / business case in mind," Cellular Operators' Association of India (COAI) said.
In its arguments, COAI pointed out that not all handsets are capable of supporting such functionalities. It also flagged concern related to privacy and confidentiality of the country's subscriber information.
Given that handset manufacturers and operating system providers have control over the data obtained through the CNAP facility, this could result in the breach of subscriber data privacy as the manufacturers of mobile devices and OS providers would amass subscriber data for the entire country, COAI cautioned.
"This would be biggest concern related to privacy and confidentiality of entire country's subscriber information, which would be akin to building up of name and mobile number database as is in Aadhaar database, with third parties," COAI said.
The association wanted to know whether any study exists on benefits of such a system.
It said a detailed cost benefit analysis should be conducted before adoption of CNAP "if at all its implementation of CNAP is to be considered in India".
TRAI must carry out a Regulatory Impact Assessment before coming out with any recommendation, COAI said.
The industry body also drew attention to technical complexities involved in implementation of CNAP and went on to say that it is extremely important that the authority shares the draft recommendation with the industry for comments and inputs "prior to finalising the same".
While there are benefits which may be derived by the subscribers from such a service, there are also several challenges towards its implementation in India, the industry said.
In its submission to TRAI's consultation paper, Reliance Jio said Calling Name Presentation should not be a mandatory service, given the limited availablility of CNAP enabled devices in India.
"...CNAP facilities is a good to have supplementary VAS service, however, in a country where over 375 million users (over 350 million mobile non broadband users and over 25 million wireline users) are unlikely to possess a CNAP enabled device, in addition to a sizable portion of the wireless broadband users that may not be possessing CNAP enabled devices as well, it can safely be said that it should not be a mandatory service," Jio said.
Jio also explained there will be many technical issues like increased load on signalling and possible impact on latency and interconnection related issues, and added "therefore, a cautious approach is recommended." "There are privacy related concerns with mandatory activation of the CNAP service on every device," Jio said.
Given the customer privacy concerns, the facility should not be mandated and if voluntarily implemented by telcos should be based on opt-in consent, Jio said.
The display of name at the time of calling can lead to various social and criminal issues.
"Therefore, it is imperative that the consent of customer is taken before activating CNAP service on his/her device," Jio said.
Jio said it is safe to assume that mandatory CNAP activation will not survive legal scrutiny.
"Furthermore, when a large section of telecom subscribers that is users on 2G-3G feature phones, 4G feature phone, smartphones not enabled with CNAP, smartphones requiring major update for CNAP, landline users etc will anyways be not able to avail this service, then the mandatory activation is a moot point and should be avoided," according to Jio.
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