GATNEAU – Groups representing deaf, hard of hearing, the blind and the deaf-blind communities told the CRTC today the Wireless Code of Conduct needs to be better tailored to their specific needs.
Specifically, the Deaf Wireless Canada Committee (DWCC) suggested videos in both American Sign Language (ASL) and Quebec Sign language (LSQ) be made to explain key contract terms. In its presentation, the association pointed to terms such as prepaid, post paid, data plan, data overages, unlocking devices, CCTS (Commission for Complaints for Telecommunications Services) and CRTC as examples. One of the problems though is that creating these videos costs money. It suggested that the wireless service providers (WSPs) should help out on this front.
“A budget for such a project would be approximately $20,000 with upkeep starting as low as $5,000 a year for updates and announcements. And this is peanuts for a multi-million wireless service company,” said Jeff Beatty, a technical consultant with DWCC.
Lisa Anderson-Kellett, chair at DWCC, suggested that the WSPs should pool their money like they do for the broadcasting and telecommunications accessibility funds (BAF and TAF) to support such a project. “That’s just an idea and hopefully we can figure out some kind of resolution and partnership so that we can work together to make sure that this is accessible,” she said.
Trials were also raised by DWCC as a point of contention. The group said that trials need to be 30 days and the amount of data needs to be a minimum of 4 GB. This is because deaf users rely so much on video and current amounts are simply inadequate to provide to sufficient testing.
“The reason that the trial is important for the deaf community is that we recently just launched VRS (video relay service) and they need to be able to access that from their work area or their home area,” said Beatty.
Media Access Canada (MAC), appearing on behalf of Access 2020 Coalition of Disabilities Stakeholders, argued in its appearance that the Commission must implement a reasonable accommodation provision in the wireless code. “Such a provision would be consistent with the strategic direction to the Commission to improve accessibility by empowering consumers with a disability to address their specific needs with WSPs,” said Anthony Tibbs, acting CEO at MAC.
He acknowledged that such a provision is less precise but that’s exactly what’s needed for persons with disabilities.
“With a broader accommodation mandate, we hope to empower consumers with a disability to more effectively communicate their concerns to WSPs.” – Anthony Tibbs, MAC
“Accommodation must be flexible and ought not be constrained to the few initiatives we might think up today and include in the code itself. With a broader accommodation mandate, we hope to empower consumers with a disability to more effectively communicate their concerns to WSPs, highlight reasonable ways in which WSPs can provide accommodation and improve accessibility, and when WSPs fail to be reasonable, escalate the conflict to the CCTS,” stated Tibbs.
The CCTS itself rounded out testimony to the wireless code’s three-year review, noting there is still a fair amount of consumer confusion on wireless contracts. This spans a number of issues but the biggest appear to be carriers continuing to treat data as an add-on and not the key term in the contract, and authorizations and overage charges for multi-user accounts.
On this latter point, the CCTS indicated some wireless companies don’t appear to be following the code with respect to consent to overage charges – and one major carrier is imposing the data overage charge on each device in a multi-user plan rather than the account as a whole.
“It offends the requirement to eliminate bill shock and that it offends Section E of the code.” – Howard Maker, CCTS
“We believe that Section E, if it is to prevent bill shock, requires that the dollar thresholds are to be applied per account, not per device activated on the account. We know that some providers are taking a different position on that, and so we believe the Commission should clarify the requirement,” said Josee Thibault, deputy CCTS commissioner.
Howard Maker, commissioner of the CCTS added that it’s one thing for the average wireless subscriber to say $50 in overages is reasonable, but another when there are perhaps four or five devices on a single account. Adding that overage charge to each of those devices could add to $250 and that doesn’t seem right, he added.
“We think that’s problematic,” he said. “It offends the requirement to eliminate bill shock and that it offends Section E of the code.”
Vice-chair of telecommunications Peter Menzies asked for the name of the carrier in question. The CCTS said it would provide the identify of the wireless operator in an undertaking with a request for confidentiality.
Earlier in the hearing, wireless operators argued that they needed to keep data as an add on rather than a key term of the contract – this means they can change this aspect of a subscriber’s plan in 30 days notice without customer consent. The CCTS said this doesn’t seem to make sense.
The customer signs up for a plan that usually includes unlimited local minutes, unlimited texting and a certain amount of data. But that data is in the form of an add on or a promotional offer. “They’re not informed that this X GBs of data is being sold to them as a promotion that under the wireless code we can change it. They don’t get that disclosure,” said maker. “So I would suggest to you that this is an issue that would be of interest to every wireless customer under a fixed term contract.”
The CCTS raised this because it believes that if wireless subscribers are able to make changes to the voice and text portions of their contracts without penalty, then they should be allowed to for data as well.
A decision from this review is expected in the spring.
