Proposal by New England Telephone for "Phonesmart" Service
(Caller ID, Repeat Dialing, Call Return, Call Trace)
Massachusetts Department of Public Utilities
Proceedings 91-64, 29 May 1991
Oral Testimony of CPSR/Boston
Written by Ronni Rosenberg, Ph.D., CPSR/Boston Member and CPSR Director
Presented by Coralee Whitcomb, Chair, CPSR/Boston
Thank you for the opportunity to speak today. I am Coralee Whitcomb. I teach
Computer Information Systems at Bentley College and am a doctoral student
in the Law, Policy, and Society program at Northeastern University. I am
testifying on behalf of the Boston chapter of Computer Professionals for
Social Responsibility, a national public-interest organization of computer
scientists.
Most of my comments are about the service marketed as Caller ID. This is
misleading, because the service identifies the phone used to place a call,
not the person making the call. To correct this misnomer, I use the name
Calling-Phone ID.
Calling-Phone ID serves the needs of businesses, not residential customers.
By linking phone numbers to reverse directories and third-party information
services, businesses can compile, then sell, elaborate dossiers of
callers-without the callers' knowledge or consent. At a phone-industry seminar
on Caller ID, the debate was framed as pitting "individual consumer privacy"
against "new billion dollar marketing and productivity opportunities." The
industry marshalls vast resources to take advantage of this opportunity.
Consumers depend on agencies like the DPU to uphold their interests, including
privacy. Concern about privacy protection is a powerful political force,
evidenced by the recent consumer uprising that prevented Lotus Development
Corporation and Equifax from marketing their Marketplace:Households product.
Calling-Phone ID satisfies business needs at the expense of residential phone
users. The central problem with Calling-Phone ID is that it infringes on the
right of individuals to control the release and use of personal information.
Phone subscribers should decide when, to whom, and under what circumstances
their numbers are disclosed. Calling-Phone ID violates a central test of
privacy protection-it compels the disclosure of personal information without
the caller's consent. When you disclose personal information without consent,
or effectively compel the disclosure as the cost of having phone service, you
diminish privacy.
NET's proposal to sell Call Blocking is unacceptable, because it is selling
back the privacy interest phone users now possess gratis. Per-call Blocking is
inadequate and onerous. Consumers will not be satisfied with stop-gap measures
that require them to do extra work, just to retain their current expectation
of privacy. Per-line blocking is needed.
Misleading marketing is directed by phone companies to residential users.
Calling-Phone ID does not provide the benefits to residential users that are
claimed. It allows subscribers only to see a "user-unfriendly" number, not to
know who is calling. Unless the caller always calls from the same number, and
you have a miraculous memory, you will not be able to convert the number into
the caller's identify. Further, the claim that residential users want to call
back their harassing and obscene callers is a marketing device that does not
reflect consumer needs.
Other services are preferable to Calling-Phone ID. Call Trace is designed
specifically to deter harassing and obscene phone calls. Last Call Return can
be used to return missed calls and talk to parents of children who make crank
calls. Answering machines can be used to screen calls. Priority Ring assures
that certain calls get answered. Call Rejection controls the calls that one
accepts, giving call recipients greater control over the invasion of their
privacy. None of these services reveals anyone's phone number without their
consent.
In addition, new services could virtually eliminate privacy problems
while vastly improving the usefulness and accuracy of the information for
residential callers. A real version of Caller ID would be a welcome service.
Real Caller ID would optionally provide the caller's identity (which could be
captured in a number of ways), not a numerical identifier best suited to be a
database key.
In conclusion, no phone number should be disclosed without the user's
knowledge and consent, except in emergencies. If a person does nothing,
subscribes to no new service, current expectations of privacy should not
change.
The privacy interests of both the call originator and call recipient can be
accommodated. Call originators have the right to decide when to disclose their
numbers. Call recipients have the right to decide whether to accept calls.
Free per-line blocking is provided now by default, because Calling-Phone ID is
unavailable. Any weakening of this policy takes a service away from customers.
CPSR/Boston recommends the following modifications to make the Phonesmart
service acceptable:
1. Per-call and per-line Call Blocking should be provided to all customers,
gratis.
2. Per-line Call Blocking should continue to be the default service for all
customers.
3. Per-line and per-call Call Rejection should be provided to all customers,
for a nominal monthly fee.
4. Call Trace should be provided to all customers, for a nominal per-use fee
(several states are considering $1 per use) and no monthly fee.
In addition, the phone company should obtain customers' approval before
using customer information for any purpose other than that for which it was
collected. The company always should tell customers why they are collecting
information and should not require that customers agree to blanket use of
information.
Finally, I urge the DPU to send the phone company back to the drawing board
to develop a true Caller ID service, one that meets the real needs of their
residential customers without compromising their privacy.
For more information:
CPSR/Boston, P.O. Box 962, Cambridge, MA 02142
Ronni Rosenberg, 67 Highland Avenue, Cambridge, MA 02139,
e-mail: ronni@ksr.com
Coralee Whitcomb, 18 Centre Street #102, Cambridge 02139, 617-864-7329,
e-mail: cwhitcomb@bentley.bitnet
