Spam or text spam is defined as the indiscriminately sending of unsolicited, unwanted, irrelevant, or inappropriate messages, especially commercial advertising in mass quantities via email or mobile phones respectively.

I have spoken about this before in my article entitled "Better Late Than Never - NTC Cracks Down on Text Spams" (http://www.infochat.com.ph/blog/?p=127).  Today, I want to talk about the suggestion of NTC to establish a Not-To-Text database.  This database will contain all the numbers of subscribers who do not want to receive broadcast/push messages.

A subscriber who does not want to receive a broadcast/push messages shall send an SMS ("REG<space>NOTOSPAM") to the NTC Text Hotline (682) so that he/she will be included in the not-to-text database. The registration through subscribers shall be charged P2.50/text to cover the cost of the telecommunications facilities and the administrative cost. Subscribers will then receive an auto reply confirming that he/she has been included in the not-to-text database, or a subscriber can personally fill up a form available at the One-Stop Public Assistance Center (OSPAC) requesting the Commission to include him/her in the not-to-text database.

Within twenty-four (24) hours, the Commission shall furnish the Public Telecommunications Entity (PTE) and the Content Providers (CP) with a copy of the list of subscribers included in the not-to-text database. Within twenty-four (24) hours from receiving the said list, the PTEs/CPs shall no longer send any Broadcast/Push messages to those included in the list.

Let me first commend NTC and its commissioners led by Commissioner Ronald Oliver Solis, Deputy Commissioner Jorge V. Sarmiento and Jaime M. Fortes Jr. for the effort and for trying to find a solution to this ever-growing problem.  Here are my observations and comments my Commissioner friends and I hope you take this constructively.  Of course what was issued are simply General Measures and Guidelines, the Implementing Rules and Regulations are yet to be issued.  So what I am going to say here are entirely scenarios - the things that can possibly happen or should not happen.

1.  Why would a subscriber pay P 2.50 just to be included in the Not-To-Text database?  They didn't ask to be sent text spams on the first place. 

2.  Let us say there are Twenty Million subscribers to date and only half of them decided to register - which will make it Ten Million.  P 2.50 for each text will amount to P 25,000,000. Now I am not sure where the P 2.50 will go to but given the 70%-30% share between the telecom providers and CPs, the telecom providers will get the P 17,500,000 and the CP, in this case NTC will get the P 7,500,000.  Not a bad revenue for a solution to a problem that they created. 

3.  The next gray area here is who will be responsible for the Not-To-Text database?  Who will maintain the servers that will contain these numbers?  There are two possibilities, it either the NTC will setup its own facilities/servers or NTC will partner with an existing CP.  Maybe this is what NTC means by telecommunications facilities and the administrative cost as the justification for charging P 2.50.

Based on the guidelines, the Commission shall furnish the PTEs/CPs with a copy of the list of subscribers included in the not-to-text database.  Now when you say copy, I am assuming that the list will be transmitted electronically from the NTC or CP server to the PTEs and other CPs servers.  Again, another sets of questions arises:

1.  Will the transmission be done in real-time?  If not, what's the time frame?  The Commission said within twenty-four (24) hours from receiving the said list, the PTEs/CPs shall no longer send any Broadcast/Push messages to those included in the list. 

2.  A system should also be in place to segregate the numbers for Smart, Globe and Sun.  NTC will be sending Smart Not-To-Text numbers to Smart only, Globe Not-To-Text numbers to Globe only and Sun Not-To-Text numbers to SunCellular only.  Just want to remind NTC that the telecom operators are very sensitive about giving away their subscribers to another telecom providers.

3.  Going back to our example that Ten Million subscribers did register, all the CPs will get these Ten Million numbers.  In effect, the CPs gets to share all the numbers - numbers that they are already servicing and the numbers that are not part of their existing database. 

So as you can see, the proposal still has a lot of loopholes to address.  It will create a big mess if something goes wrong somewhere.  And it can give undue advantages and/or disadvantages to some of the CPs.  Following the idea of NTC, why don't we reverse the procedure.

1.  Telecom providers should provide a hotline access code for their subscribers to register for their own Not-To-Text database.  Smart subscribers will register to Smart, Globe subscribers to Globe, and Sun subscribers to SunCellular.  Since the subscribers will text using their own respective networks, the P 2.50 fee can be waived.  It can be done Free of Charge.  Don't make money out of this please.

2.  The telecom providers should also issue a confirmation number as part of their reply message that is unique which the subscriber can keep if ever problem will arise later on.  This will prove that the subscriber indeed register to be part of the Not-To-Text database.

3.  Telecom providers should now be the one to furnish NTC of their Not-To-Text databases with confirmation numbers in real time, which NTC can use later on if a complain comes in.  If the complainants' number is already included in the Not-To-Text database and if he/she can show proof (confirmation number) but he/she still receives text spams, then NTC can now imposed the penalties to both the telecom provider and the CP concerned. 

This will not only save NTC a lot of money in terms of telecommunications facilities and the administrative cost, it will enable NTC to do their other tasks.  NTC was not created for the text spam alone right?

This will also simplify the entire procedure.  Rather than giving the lists to PTEs/CPs, the broadcast message can be filtered in the telecom providers' end, since all messages will pass through them anyway.  Any messages that will contain numbers included in the telecom providers Not-To-Text database will be blocked. 

The telecom providers can also opt to send their Not-To-Text database to their respective CPs as well if they want to, so that the CPs can do their own filtering.  This will also eliminate the possibility that Smart will have the Globe list of subscribers and Globe will have Smart list of subscribers.  Competition and advantage over the other will be maintained.

What I don't want to happen here is for NTC to be accused of using this as a source of revenue and/or as a business, or favoring one CP or one telecom provider.  NTC is a regulating body, it should exclude itself in the procedure or be part of the operation.  This is one way for NTC to stay neutral, effective and maintain its credibility in the mobile space.  And at the same time, I want the Not-To-Text solution to work so that we can put an end to this text spam problem.

Am logging off.  Stay cool and God Bless us all!

**********

For your questions, comments, suggestions, press releases and stories, please e-mail techtvhost@yahoo.com or visit www.infochat.com.ph for more articles.