Distributed Ledger Technology - An Adequate Way to Protect Yourself from Unsolicited Commercial Communication - TRAI Update

Mobile Marketing has emerged as a cost effective marketing channel to boost business growth with significant impact. But do you know utilization of this tool generates disturbance and inconvenience for telecom users. Even it conquers the privacy of public and enhances the unsolicited calls and SMSs.

Telecom Service Providers facing Unsolicited Commercial Communication, which is one of the major challenges and disturbing headache these days. According to Telecom Regulatory Authority of India (TRAI) Update - The main purpose of the Distributed Ledger Technology (DLT) is to reduce spam messages and eliminate fraudulent activity through Unsolicited Commercial Communications efficacious as of August 1st, 2019.

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Looking at the various disturbing aspects of this problem faced by the Telecom users TRAI decided to notify new guidelines for curbing this big menace of Unsolicited Commercial Communication Because In May, 2018, TRAI released Telecom Commercial Communication customer preference Regulation 2018 including the use of Blockchain or Distributed Ledger Technology to check the nuisance of Unsolicited Commercial Communication because TRAI has received a total of 83,908 complaints from telecom users receiving pesky calls despite opt for Do Not Disturb (DND) service in the last six months.

How Distributed Ledger Technology Works and Why it's Important

Distributed Ledger Technology (DLT) is worthwhile way of Technology to deal issues related to integrated database synchronized at diversity of platforms like internet, institutions, sites and countries etc. 

DLT also helps in preventing cyber attacks also as it allows public witnesses across the geographies. The platform or Technology on which the concept of Distributed Ledger Technology is based is 'Blockchain' which in turn made up of digital blocks of information to stop or obstruct harmful or disturbing unsolicited commercial communication. Distributed systems use a connected network of devices and databases to share authority with each node to create shared accountability and the pooling of resources to manage the ledger.

In simple words, DLT can be explained as a ledger of a database, contract or transaction which is maintained and shared across the globe, thus need not to have a supervising nucleus command to control or secure it.

The purpose of DLT is to replace trusted third parties that process and store records in a centralized manner with decentralized computer protocols where every user on the network verifies the accuracy and authenticity of all records in one singular, non-centrally-owned ledger. 

DLT replaces current system rule — a probabilistic world where value exchange is run by humans and so rules will probably be followed, with system law — a deterministic world where value exchange is run by immutable computer code and exchange is determined directly by reliable, unbiased, and tamper-proof data.

Advantages of DLT :
  • Reduce UCC - 'Blockchain' or DLT is competent enough to record details of calls, massages, contents headers etc which is a key to ensure blockages of Unsolicite d Commercial Communication.
  • Security - DLT solutions are unique as ledger of DLT enable records enormous number as a secure tool.  It can integrate business rule, smart contract, digital signatures etc. DLT Replicates data with security and accuracy as Entries reflected in all copies in seconds. Robust verification and authentication of telemarketers and other entities.
  • Restrict Unauthorized Changes - DLT is Resistant to unauthorized changes, it match copies with participants and change only after consensus.
  • Diversity of Utilization of DLT - Experts believe digital ledgers can be used in tax collection, property deed transfers, social benefits distribution and even voting procedures. Much of the early interest in distributed ledger technology has been around its application in financial transactions. Data maintained cryptographically through keys and signatures.
  • Securing Client Database
  • Management of headers structure, lifecycle and contracts between entities.
  • Registration and verification of content template and Recording of consent in verifiable manner.
  • DLT Use for - Recording preferences, Recording and verification of consumer consent, Complaint handling, Intelligence, Registration of entities, Registration and verification of contents.
Future of DLT

     DLT is sufficiently reliable to put into wide-scale use because DLT is uniquely suited to achieving greater transparency. There are a variety of protocols offering off-chain solutions for scaling, interoperability, and privacy. It will be interesting to see if second layer solutions fix the inherent problems of distributed ledgers or only offer band-aid solutions with their own tradeoffs.

In the future, systems based on DLT could enable new services.

Commercial Communication Market in India - Industry Overview, Market Size & Growth

India is the fastest growing market and if we talk about Commercial Communication Market, it’s rapidly increasing. Telecom Commercial communication is one of the optimum solutions of marketing in India especially with 1.2 Billions mobile users and if we talk about the DND registered Subscribers, it lies as 230 millions.

According to a conservative estimate approximately 30 Bn massages are sent from Marketers to the users. Out of total telemarketing companies only 20% are registered .Rest is creating a huge issue or problem both for TSPs and users.

New Regulations To Be Followed to Stop Unsolicited Commercial Communication
  • Register Required - From now, Each and Every Telemarketer should be registered with TRAI. 
  • Promotional Message Restriction - Consumers will not receive promotional messages if they are register with NCPR. As per TRAI guidelines, 'Promotional Calls' cannot be made to customers who have registered themselves in the NCPR.
  • Synchronize Headers - It’s very vital for Telemarketers to separate headers for Transactional and Promotional messages.
  • Differentiate the Number Series - In case of Telemarketing Voice call, Separate number series should be arranged.
  • Signature Identification - One of the crucial things to be done by telemarketers if you are sharing Bulk SMS is to take Signature identification.
  • Register Preference - Requiring telemarketers to send messages as per registered preference.
  • Provision of Disconnection - All telecom resources and blacklisting for two years if telemarketing activities by unregistered entities. 
Challenges Faced To Follow This Regulation
  • Time Consuming to do formalities like registration and deregistration.
  • Cases of victimization
  • New Techniques Found, such as robo calls and silent calls which may be of concern to the customer
  • Non-Traceability Issue of Senders of UCC, and intermediaries generated.
  • Transactional Message headers Abused to Send Promotional Messages
  • Customers Doesn’t Have the Choice To Revoke Such Consent - Consent taken by organizations or individuals to send transactional messages were unverifiable and accessible and customers has no such kind of choice to dismiss this.
  • Disconnection of Telecom Resources - Despite disconnection of telecom resources, UCC from Unregistered Telemarketers were increasing.
  • UCC Complaint Resolution - In case of UCC complaint resolution long time window and action against defaulter is more than seven day.
Features of New Regulation
  • Technology Driven and Encourages Automation
  • Reduce the burden on access providers
  • Code of Practices by TSPs
  • Brings efficiency in UCC Ecosystem
  • Stream lining of processes
  • Use Cloud Services
  • Each function to maintain separate log of activity.
  • TSP to frame Code of Practices and compliance through technology
  • Distributed LedgerTechnology (DLT) Mandatory forAccess Providers to adopt
  • Setup a Regulatory Sand box for testing implementation of regulatory checks using DLT networks.
Important Aspects of DLT
  • Reconciliation Through Cryptography
  • Replicated to many Institutions
  • Granular Access Control
  • Transparency and Privacy
  • DLT has potential to offer solution with better management and control
  • Automation, Flat architecture, Speed, sharing of data, shared cost
  • Adaptability of DLT to meet evolving requirements, intelligent and programmable contracts.
DLT Networks Types 
  • Public - Transactions occur between any two parties, from any computer, at any location. The nature of the technology allows it to be secure, and no one entity has full control over it.
  • Private- Private DLT is gaining traction. In this context, DLT is used more as a database than as something to be openly traded and agreed upon.
  • Consortium - Consortium DLT is a hybrid of public and private structures. Consortium DLT relies on consensus just as public DLT does, but assigns permissions on which nodes have the authority to approve which transactions.

Benefits of DLT - It would be beneficial for everyone including Customers, Access Providers Business Entities & Telemarketers. 

For Customers 
  • Avoid victimization
  • Avoid Inconvenience because of UCC from UTMs
  • Enables faster resolution of UCC related complaints and Implements choices to come very quickly in to force.
For Access Providers
  • Avoid loss of business opportunities
  • Reduce regulatory burden
  • Provide opportunity to test and develop new processes 
  • Provide capability to trace default ingentity in case of non-compliances entities.
  • It provides ease to do business
  • Reduce risk as chances of flouting of regulatory compliances would be less
  • Lower upfront cost to start telemarketing business
  • Enhance volume of business due to flexible options to customers as many may like to receive such messages in their leisure time
  • Enhance business opportunities for them as they can participate in new functions and roles such as consent acquisition
Business Entities
  • Enhance business opportunities
  • Enable to keep client data in safe and secure manner
  • Protect Brand Credentials as it would provide capabilities to display their identity after authentication
  • Lower risks because of avoiding chances of non-compliances
  • Provide options to connect directly with the entities that are actually carrying out regulatory functions.
Distributed Ledger Technology is an effective way to deal with Modern Menace of Unsolicited Commercial Communication. It's efficient resource for safe and secure data handling and Building more confidence in the UCC ecosystem for the Principal entities. The main objective to be met by technological solution is to protect consumers, Protect interests of telecom service providers and Promote competition and to use sensitive information in secure manner. Broad spectrum of distributed ledger models - Different degrees of centralization and different types of access control, to suit different business needs.


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