July 10, 2001

Secretary General
Canadian Radio-Television and Telecommunications Commission
Ottawa, Ontario
K1A 0N2

RE: RE: PUBLIC NOTICE CRTC 2001-56
Operator services - Reverse search directory assistance

1. As part of its mandate, the Office of the Information and Privacy Commissioner/Ontario (IPC) comments on the privacy implications of emerging or existing information practices and services. In keeping with this mandate, we would like to comment on the appropriateness of telephone companies providing reverse search directory assistance services, and appreciate the opportunity to do so.
   
   
2. In our view, it is not appropriate for telephone companies to provide reverse search directory assistance services. If such services were made more widely available to the public, the overall effect would be to diminish telephone customers' privacy. It is our view that the provision of reverse search directory assistance does not promote any of the objectives of the Canadian Telecommunications Policy as set out in section 7 of the Telecommunications Act and is in direct conflict with the objective to "contribute to the protection of privacy."
   
   
3. When individuals provide a telephone number for others to contact them, they generally do not expect others to be able to use this information to determine who they are and where they are located. For example, individuals who advertise goods and services in newspapers often provide their telephone numbers as a means for others to contact them. If others could readily ascertain a name and location from a telephone number only, this not only threatens the individual's privacy, but could also result in harm. For example, through a reverse directory search, thieves could identify the location of expensive items such as cars, jewellery or furniture.
   
   
4. In addition, reverse search directory assistance, in combination with Call Display, would allow individuals to know the names and addresses of all callers who do not block their number. Currently, callers have the option of replacing their real name with "Private Name" or blocking their name and number on a per call basis. If the reverse search directory assistance service were widely available, individuals would have to block each call to prevent others from being able to determine their name and address. Since recipients often reject calls made using the blocking feature, customers may not view this as a viable privacy protection option. To maintain the effectiveness of the current Call Display privacy features, telephone customers would have to be able to opt out of having their names and numbers made available through the reverse search directory assistance service.
   
   
5. The provision of reverse search directory assistance in conjunction with Call Display also facilitates data matching and profiling. For example, commercial enterprises could use this service to determine the names and addresses of individuals who call to inquire about specific products or services, without their knowledge or consent. This information could be used to market certain products and services to those individuals. Unsolicited mail and telephone calls from direct marketers are generally viewed as a nuisance. Such contact seems particularly intrusive where the marketer appears to have personal information about the individual that was obtained from a source other than directly from the individual.
   
   
6. Reverse search directory assistance service in conjunction with information about an individual's calling patterns (e.g., a listing of incoming and/or outgoing calls on a telephone bill) could reveal very sensitive information about an individual. Specifically, it could reveal the names and addresses of all friends, family members and business associates who are in contact with the individual by telephone. Consequently, the widespread availability of reverse search directory assistance would make information about an individual's incoming and outgoing calls extremely sensitive.
   
   
7. The fact that the information from reverse search directory assistance may be available from other sources, beyond the oversight of the Commission, does not minimize the inappropriateness of the telephone companies making this information more readily available to the public.

Thank you for considering our views on this matter.

Sincerely yours,

Ann Cavoukian, Ph.D.
Commissioner