Distributed Ledger Technology (DLT) - FAQ

Important Definitions :

Access Providers:includes the Basic Telephone Service Provider, Cellular Mobile Telephone

Service Provider, Unified Access Service Provider, Universal Access Service Provider and Virtual

Network Operator (VNO) as defined in the respective licenses issued by Department of Telecommunication

Commercial Communication: Means any voice call or message using telecommunication

services, where the primary purpose is to inform about or advertise or solicit business for

(A) goods or services; or

(B) a supplier or prospective supplier of offered goods or services; or

(C) a business or investment opportunity; or

(D) a provider or prospective provider of such an opportunity;

Explanation:

For the purposes of this regulation it is immaterial whether the goods, services, land oropportunity referred to in the content of the communication exist(s), is/are lawful, or otherwise.

Further, the purpose or intent of the communication may be inferred from:

(A) The content of the communication in the message or voice call

(B) The manner in which the content of message or voice call is presented

(C) The content in the communication during call back to phone numbers presented orreferred to in the content of message or voice call; or the content presented at theweb links included in such communication.

Consent:Means any voluntary permission given by the customer to sender to receivecommercial communication related to specific purpose, product or service. Consent may beexplicit or inferred as defined in these regulations

Consent Template:Means a template of content which is presented to the customerwhile acquiring his consent and clearly mentions purpose of the consent and details of sender

Content Template for Transaction:Means a template of content registered by any senderwith the access provider for sending transactional message, service message or transactionalvoice call, service call for the purpose of commercial communication and contains contentwhich may be a combination of fixed part of content and variable part of content, where

i) fixed part of content is that part of content which is common across all commercialcommunications sent to different recipients for same or similar subject;

ii)variable part of content is that part of content which may vary across commercialcommunications sent to different recipients for same or similar subject on account ofinformation which is very specific to the particular transaction for a particular recipient ormay vary on account of reference to date, time, place or unique reference number

Content Template for Promotion:Means a template of content registered by any senderwith the access provider for sending promotional message or promotional voice call for thepurpose of commercial communication and contains content which is fixed content andcommon across all commercial communications sent to different recipients for same or similar subject .

Content Template Registrar:is an authorized entity under the relevant regulations responsiblefor maintaining the Content template register and Content template registration facility;

Customer Preference Registration Facility:Means the facility established by an AccessProvider, under relevant regulations, for the purpose of registration, modifications or deregistrationof the preference of its customers in respect of receipt of commercialcommunications;

Distributed Ledger Technologies (DLT) : Means a set of technological solutions that enables asingle, sequenced, standardized and cryptographically-secured record of activities to be safelydistributed to, and acted upon, by a network of varied participants and their

i)                    database can be spread across multiple sites or institutions;

ii)                   records are stored one after the other in a continuous ledger and can only be added when the participants reach a consensus;

Explicit consent :Means such consent as has been verified directly from the Recipient in arobust and verifiable manner and recorded by Consent Registrar as defined under theseregulations;

Fully blocked :Means stoppage of all types of commercial communication requiring explicitconsent except commercial communication sent under inferred consent;

Inferred Consent :Means any permission that can be reasonably inferred from thecustomer’s conduct or the Relationship between the Recipient and the Sender;

One Time Password or OTP :Means an automatically generated random number used toauthenticate the action of user for a single transaction or session.

Promotional messages:Means commercial communication message for which the senderhas not taken any explicit consent from the intended Recipient to send such messages;

Promotional voice call :Means commercial communication voice call for which the Senderhas nottaken any explicit consent from the Recipient to make such voice calls to him;

Registered Telemarketer (RTM) :Means any telemarketer who is registered with the access provider(s) in accordance with the procedure and conditions specified in these regulations.

Robo Calls :Means any call made to any customer using an artificial or prerecorded voice tointeractively deliver a voice message without the involvement of human being on calling sidefor participating in the dialogue;

Scrubber :Means an entity registered with the access provider(s) and authorised by therelevant regulations to perform the function of scrubbing in accordance with the relevant regulations;

Scrubbing :Means process of comparing target list of telephone number(s) provided by theSender, to whom it wishes to send commercial communication with the list of telephonenumber(s) in DL-Preference and DL-Consent to check whether commercial communication(s)can be sent to the Recipient as per his registered preference(s) or as per consent;

Sender: In relation to a commercial communication, means

i)                    The person or entity who owns the telephone number or the header(s) that were used;

ii)                   A person or entity that publicly asserts or uses a Calling Line Identity (CLI) or the phone

number(s) referred to in the communication, except where such assertion is fraudulent;

iii)                 The person who sent the message or made a voice call, caused the message to be sent or

the voice call to be made or authorized the sending of the message or making of the voice

call;

iv)                 The person or legal entity dealing with goods, or services, or land or property, or a business

or investment opportunity that is offered or promoted; except where such entitymaintains a distinct legal identity for the division or line of business dealing with offeredgoods,services or opportunity, in which case such division or line of business;

Service message or Service Call:Means a message sent to a recipient or voice call made to

recipient either with his consent or using a template registered for the purpose, the primary

purpose of which is –

i)                    tofacilitate, complete, or confirm a commercial transaction that the recipient haspreviously consented to enter into with the sender; or

ii)                   to provide warranty information, product recall information, safety or security information

with respect to a commercial product or service used or purchased by the recipient;

to provide—

(A)          notification concerning a change in the terms or features of; or

(B)          notification of a change in the recipient’s standing or status with respect to; or

(C)          at regular periodic intervals, account balance information or other type of account

statement with respect to, a subscription, membership, account, loan, or comparable

ongoing; or

(D)          commercial relationship involving the ongoing purchase or use by the recipient of

products or services offered by the sender; or

(E)          information directly related to an employment relationship or related benefit plan in

which the Recipient is currently involved, participating, or enrolled; or

(F)          information relating to delivery of goods or services, including product updates or

upgrades, that the recipient is entitled to receive under the terms of a transaction that

the recipient has previously consented to enter into with the sender

Silent Call : Means any unsolicited call made by a person or an entity to a customer for a veryshort duration in which either called party has not yet been alerted by his or her device, or itis very unlikely to be answered, wherein the intention of caller is to get call back from calledparty and then enter into commercial communication;

Telemarketer: Means a person or legal entity engaged in the activity of transmission ordelivery of commercial communication or scrubbing or aggregation.

Terminating Access Provider” (TAP): Means the Access Provider of which Recipient ofcommercial communication is a Subscriber;

Transactional message:  Means a message triggered by a transaction performed by theSubscriber, who is also the Sender’s customer, provided such a message is sent within thirtyminutes of the transaction being performed and is directly related to it.

Provided that the transaction may be a banking transaction, delivery of OTP, purchase ofgoods or services, etc.

Transactional Voice Call :Means a voice call which is not promotional in nature and is for the

purpose of alerts to its own customers or account holders and information to becommunicated by the voice call is time critical in the nature;

Unregistered Telemarketer (UTM) :Means any Sender of commercial communication whois not registered for the purpose of telemarketing with the access provider(s);

Unsolicited commercial communication or UCC: Means any commercial communicationthat is neither as per the consent nor as per registered preference(s) of recipient, but shall notinclude:

i)                    Any transactional message or transactional voice call;

ii)                   Any service message or service voice call;

iii)                 Any message or voice calls transmitted on the directions of the Central Government or the

State Government or bodies established under the Constitution, when suchcommunication is in Public Interest;

iv)                 Any message or voice calls transmitted by or on the direction of the Authority or by an

agency expressly authorized for the purpose by the Authority.

What changed after the implementation of new guidelines?

Current Scenario		New Regulation	Remarks
Customer Consent	No	Yes	Verifiable digital records of all customer opt-ins are made available on the platform. Customers can also see all their consents on a single dashboard
Customer Preferences	Yes	Yes	Consumers can also select specific day(s) and time band to block (or) receive. commercial communication in addition to type of category; viz only DND
Entity/Enterprise Registration	No	Yes	Entity need to register with originating access provider (OAP) on the platform
Telemarketer Registration	Yes	Yes	Telemarketer should now register with originating access provider (OAP) and no longer with TRAI
Header Registration	No	Yes	Entity should register all its SMS Headers and Voice CLIs on the platform
Template Registration	No	Yes	Entity should register all its templates (consent & content) on the platform
Type of Messages	Transactional Promotional Govt	Transactional Promotional Service (Inferred Consent) Service (Explicit Consent)	Every template should be registered under one of these classifications: Promotional,Transactional or Service (Implicit or Explicit) Government messages are classified under Service category
Scrubbing	Yes	Yes	Messages will be scrubbed against multiple parameters like Consent, Preference, Header, Template; and not just DND list
Complaint Management	Yes	Yes	Telecom operators will now be responsible for complaint resolution
Interoperability between telecom Service Providers	No	Yes	Registration details of Entity, Telemarketer, Header, Template will be shared across the network to ensure seamless view
100% Traceability	No	Yes	Everything is recorded and shared on the network using Blockchain technology.

Few Ground rules

• Entity/Enterprise owns the rights of all Headers and Templates.
• A telemarketer can create Headers and Templates on behalf of an entity if authorized by Entity through authorization letter but TM does not own them.

• Every single Header and Template needs to be registered on the platform via respective operator

• Anything that gets registered on the platform will be made available to all other operators. Register once, access across.

• Every single message will be scrubbed before delivery.

• Consent overrides preference. A user with Fully-Block will get a message, if the consent is given to that entity.

• Entity need to share one time consent data for migration

• Consent received from end subscriber has valid for 12 months ( may change as per TRAI directives)

• Consent needs renewal after 12 months

Q :Registration Fees : For Telemarketer it is 5 K+50 K (security)  & 5 K per entity however Access Provider/Operator is not sure if other DLT provider/ Operator will charge the same or not. If TM is connected with four operator /DLT then will fees will be paid to all or only first registration. Need  clarity

Vcon : If the TM is registered with One entity then the same registration number will be acceptable to all the TAPs. The fee needs to be paid only to the first TAP but KYC & Agreement and other document formalities needs to be done separately. Fees are mentioned below:

a)      Entity Registration : Rs.5000 + GST

b)      TM Registration : Rs.5000 + GST

c)       Entity + TM Registration: Rs.5000 + GST

Q :Sender ID and Template ID related: Sender ID and template will automatically be synched across DLT platform however TM need to enabled them by requesting to Other operator with reference ID received from one DLT platform. This point also could not be clear with respect to TAT/ internal/ external process between the operator.

Vcon : Header & Template are whitelisted against an entity ID which flows in the DLT. If the entity gets registered with the second TAP using the same registration number the whitelisted Header and & Template will immediately be synched.

Q :For Promotional Campaign : Delivery reports will not be shared however clarity not shared how campaign summary will be shared in automated way.  As per you the same will visible in DLT Platform, Need clarification how same will be shared with customers.

Vcon: The Account wise Summary Report will be available in a similar manner as is being done currently.

Q :Changes for TM in SMS submission: As per Operator we need two additional parameter i.e. entity ID and Template ID while submitting the messages to operator , Clarity is not there if same parameter will work with other Provider or not.

Vcon : The Entity ID and Template IDs will be same across all Operators

Q :Exiting Data migration / Consent : operator could not clarify us how existing  templates/ sender will be migrated.  As per them “This needs to be validated further and clarity will be shared by end of this month”

Vcon : Consent is still under discussion among the operators.

Q :  DND Check: As per operator DND check will not be required at TM side however scrubbing can be done. Complete flow and queries could not on this.

Vcon : Scrubbing can be done at Operator end only  and Scrubbing as a Service will also be made available .

Q :Sender ID Fees: As per regulation sender ID registration was  chargeable however as per Operator it is waved off for few month.  Need details / confirmation by when they will start this process .

Vcon : No clarity from any operator as to from when it will be charged.

Q :Optin Related: As per Demo operator will have details of customer Optin which is currently offline for them as entity do take opt in in their CRM/website. Need clarification how end entity will pass opt in details in real time scenario

Vcon: If your referring optin to customer consent then this will be cleared after the discussion among the TSPs on Consent Mechanism

Q :Changes in regulation: As per operator there are certain regulation point changed by operator after their internal discussion. We need all updated points

Vcon : As per our understanding there is no change in the regulations. All the TAP / OAP process are being drafted around TCCCPR 2018

Q :Migration/ Go live Plan: Operator is still not certain on dates / migration plan hence we will not be able to communicate customer further.

Vcon: 1st of March 2019 is implementation date for Regulation. Now we immediately have to registered TM/Entity on DLT platform and need to register header/template for subscribing against the preferences.     

Q :In present scenario we send sender id whitelisting request to multiple operators, after cross checking all the details respective operator rejects or approves the sender id, but in regulation it’s not clear if a particular sender id gets approved from 1 of the operator then by default it remain approved by rest of the operators or not.

Vcon:  Sender ID / Header getting approved / rejected against the Principal Entity will automatically flow in the DLT.

Q :In present scenario, enterprise reach out to us directly for template whitelisting, once done we confirm back to them to send the message. But in regulation if an enterprise directly gets the template approved, then how will TM come to know which template is approved for particular enterprise, so that we can also upload it on our server.

Vcon : Once the entity gets the Sender ID approved it has to allocate the same to the TM along with the approval document . TAP will approve the allocation of Header / Sender ID to the requested TM after validating the approval document. Till the time it is not approved by TAP , TM can see the Header in the pending status.

Q :What will happen in case customer send some wrong templates, wrong sender id

Vcon :  Will be rejected

Q :Who will maintain blacklisting number list, also in the span of time TM has some blacklisted database list maintained by ourself

Vcon : TM to maintain all such list at their end and ensure that it is not the part of the file uploaded.

Q :Error codes in case of different failure cases like messages not getting delivered in case they lie in NDNC especially for promo.

Vcon : No Delivery Status/Error codes will be shared

Q :How MNP data is managed and will it be shared with us.

Vcon : MNP Data lies with Operator only and is not shared by us currently also

Q :  How spam management is done and who will be responsible.

Vcon : SMS Spam Management & UTM calls to be handled through UCC_Detect Mechanism .  Responsibility will lie with the concerned Principal Entity .

Q :Operator circle data/series is manages by TM as routing of traffic is done accordingly also this helps in smooth flow of traffic, also updation of new series/operators happens at our platform, so what will be the future course of action.

Vcon : Series Data lies with Operator only and is not shared by us currently also

Q :In case of promo pipe, what will be user type > trans, trans-receiver or receiver.

Vcon : Only TX as no DLRs to be provided

Q :What will be parameter name of entity id, pdu parameter sequence and templateid in submit smpdu.

Vcon : Will share post finalization across TSPs

Q :How waiting is handled in case of dlr not received/Promo or will we get error code for the same.

Vcon: No Delivery Status/Error codes will be shared

Q :What will happen to VIP/Important personnel numbers as we avoid sending any messages to them.

 Vcon : TM to maintain all such list at their end and ensure

Q :If a Customer is registered as a Tele Marketer with us by paying Rs 5000 + GST as registration fee, Does he need to pay registration fee of Rs 5000 + GST with other operators also? Or Only KYC, Agreement and other documents need to be given to other operators once registration is completed with first operator

Vcon :Only basic information will be flowing through DLT , all other documentation needs to be completed with the new operator. TM registration fee is to be paid only once to the operator with which TM is getting registered initially.

Q :There are customers who have registered as TM but not paid Rs 5000/- yet. How can we identify? Eg: customer ABC had submitted all documents and registered but have not paid registration fee and security deposit

Vcon : Account will be in pending state and will be approved only after the relevant fee along with documentation is completed.

Q :Is Security Deposit of Rs 50,000 mandatory for all Tele Marketers to pay apart from Registration fee? As few customers claimed that other operators have not asked for the same.

Vcon –It is mandatory for all the operators which is refundable.

Q:Does Customer have to pay Security Deposit of Rs 50000 with other operators also?

Vcon : Its operator’s call

Q :Does Entity needs to be registered separately with all operators? Or Only KYC, Agreement and other documents need to be given to other operators once registration is completed with first operator

Vcon :Post registration with one operator an Entity ID gets created, basis this ID entity can get registered with any other operator post completing their document formalities.  

Q :Is there any Entity registration fee applicable? If Yes than does the Entity needs to pay registration fee with all operators

Vcon :Entity registration Fee 5000+  18% GST – 5900, no its one time only

Q :Can the Customer give request for more than 6 digits Sender ID approval on new portal for whitelisting.

Vcon : To start with industry will be going with the old Sender ID limit of 6 digits.

Q :Who has to approve the sender ID with Telecom Service Provider TM or Entity?

Vcon :Operator will approve the header.

Q:Is there a limit for sender ID’s against each entity

Vcon : No.

Q:In Case of Enterprise Customer who will be buying directly SMS connectivity from us, he needs to register as a TM only with us by paying Rs 5000/- Registration fees or even as an Entity? Does he need to pay Rs 50,000/- deposit also?

Vcon : If the enterprise is intended to send SMS to its customer directly then they have to register both as entity and TM by payment TM registration fee and security deposit.

Q:Will there be change in delivery reporting structure with new guideline ( submission/Delivery)

Vcon :Still to be worked upon

Q :In Case of UCC complaints , will the same process of current opt in’s will be followed.

Vcon : Yes, in case of any change will be updated

Q :Is the old TM licence issued by TRAI valid

Vcon : TM needs to get registered on the DLT platform and get new TM Licence which will be recognised by all the operators.