SilentCallsVictim
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Having been invited to comment, I will offer some thoughts, although I have not studied this issue in any depth.
This seems to be an attempt to address the problem caused by the fact that there has never been any proper arrangements for the assembly of a proper directory database of mobile numbers, with proper procedures to cover opting in or out.
Firstly, I address the "privacy" issues raised by this service.
I personally have my name, address and (main landline) telephone number listed in the normal telephone directory. I see no reason why this information should not be publicly available, despite the fact that some banks are content to steal my identity by granting it to anyone who accesses this information.
Being engaged in society I have no problem with the basic fact that I receive unsolicited communications. These are sometimes welcome, even though they are mostly worthless. I am able to apply filtering mechanisms for my convenience and do so. I nonetheless fully respect the right of anyone (individual or corporate) who wishes to opt out from their contact information being available in certain forms.
The ICO (which is not a government body, contrary to the false statement on the 118800 website) enforces regulations designed to protect the right to privacy. Although its enforcement policies are hopelessly weak, as they are based on a consumerist approach, I find its principles of what is acceptable to be generally sound.
As ever, the devil is doubtless in the detail of how the information is collected and used. If I became aware of a problem I would look into this very carefully and take up the issues with the ICO.
Secondly, from the perspective of the service user.
PhonePayPlus is a self-regulatory body. To my mind any such body has an inherent conflict of interest which must make its role as a regulator an alternative to, not a means of implementing, statutory regulation.
Excessive advertising has happily communicated the fact that 118 numbers belong to commercial services, rather than being inclusive with one's telephone service (like printed directories). I would doubt that anyone would contact 118 800 without being aware of the fact that they were entering into a commercial arrangement and so the principle of caveat emptor must apply. Any misrepresentation that is found would be a matter for Ofcom (via PhonePayPlus) or Trading Standards.
A quick response to the concern about a request to be ex-directory causing details to be added. As with the TPS, there is no confirmation of the authority to add the number to the list. An ex-directory request could only be used to add to the directory if the name and address were already held as they do not need to be supplied. Furthermore, one could make such a request for any number. It is however likely that measures are in place to detect mass requests for every number in a range. (When BT started passing on TPS registrations with the launch of its BT Privacy service, there were allegations that it was registering numbers without request, simply to protect its existing customers from being recruited by telephone by its competitors - that was its commercial justification for BT Privacy.)
I hope these comments are of interest to members.
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