File No.: 8665-C12-201211317
Ottawa, 28 September 2012
President and Chief Operating Officer
Canadian Wireless Telecommunications Association
1110-130 Albert Street
SENT BY EMAIL: firstname.lastname@example.org
RE: Mobile Device Theft and the Canadian Wireless Telecommunications Association Response
This is further to your letter dated 13 August 2012, which was in response to the Commission staff letter dated 17 July 2012 regarding mobile device theft and the Canadian Wireless Telecommunications Association’s (CWTA) actions to address this issue.
The Commission takes the issue of lost and stolen mobile devices seriously, including potential privacy concerns, and to date is not satisfied with the responses filed with the Commission by the CWTA.
As you noted in your letter, the Commission is seeking information related to the following:
The Commission requests that the CWTA submit responses to the following items by no later than 30 November 2012.
With respect to the question of statistics and their availability, though the Commission appreciates that there may be some challenges related to the coordination of the collection of statistics in the short term, the Commission does not view a timeframe of “late 2012 or early 2013” as reasonable. As such, the Commission considers an additional 60 days is more than sufficient for the CWTA to survey its members and to process the data, especially in light of the fact that it became aware of the Commission’s request for the statistics two months ago. As noted in the Commission staff letter dated 17 July 2012, if the CWTA intends to submit any information confidentially, the CWTA is to also submit an abridged version.
CWTA Handset Security Working Group
On the topic of what initiatives the wireless industry has undertaken, the Commission is pleased to note the creation of the ‘CWTA Handset Security Working Group’ and looks forward to seeing the results of the efforts of this Working Group. However, the Commission would like further information about this Working Group, such as an identification of its membership, an indication of how often this Working Group meets, what resources have been allocated to it, when it is expected to report back to the CWTA and whether or not consideration has been given to inviting law enforcement officials to sit, at minimum, as observers on the Working Group, to ensure a holistic approach to this issue.
Public Education Campaign
The Commission acknowledges that the Canadian wireless industry is just one element of what needs to be a multi-stakeholder and multi-prong solution to the issue of mobile device theft, and concurs with the CWTA that an informed consumer will be better able to protect him- or herself in the instance of a lost or stolen handset. However, the Commission is requesting additional details regarding the “public education campaign” proposed by the CWTA, such as what elements will be included in the campaign, what resources have been allocated to the campaign and specific timeframes for launching the campaign. Though the Commission appreciates that the U.S. wireless industry is engaged in similar activity, it is the view of the Commission that the Canadian campaign does not need to be launched concurrently. To that end, the CWTA is to provide, in addition to the requested information, a clear explanation as to why such a campaign could not be launched before 2013 in light of the fact that the industry has been considering this issue since the spring of 2012 with the creation of the ‘CWTA Handset Security Working Group’ and the resources available to the Canadian wireless industry.
The Canadian wireless industry can also help address the issue of the theft of mobile devices by reducing the value of the devices through having lost and stolen handsets registered in a central registry. The Commission acknowledges that some time and resources would be needed to create a Canadian database, but notes that there are international initiatives, such as the International Mobile Equipment Identity (IMEI) database, which are available. The Commission is not convinced by the arguments put forward by the CWTA in its 13 August 2012 letter against joining the IMEI database, especially as the Commission is aware that at least one of the members of the CWTA is using that same database for reporting the theft of mobile devices from its retail storefronts. The CWTA is to provide to the Commission a detailed explanation of the costs and barriers Canadian carriers would face in joining the IMEI database.
It should be noted that if the Commission is not satisfied by the response of the Canadian wireless industry to this issue, the Commission will investigate what further regulatory action needs to be taken to provide the necessary tools to help consumers in this regard.