Is Government’s proposed Caller Name Presentation of all incoming phone calls, a solution looking for a problem?

Image top: Look who's calling. Image credit: Truecaller
Image bottom: Early days of caller ID_ BSNL's CLIP phone
TRAI has issued a paper suggesting that telecom service providers should provide a subscriber with the name of the caller in addition to  his or her telephone number. Stakeholder comments raise issues of privacy as well as some technical hurdles. Free apps like True Caller already provide this service – but with poor success rates sine their information is crowdsourced
By Anand Parthasarathy
January 28, 2023: Take your mind back some 23 years to the turn of the century, when mobile phones were still a luxury and  a telephone meant a landline from BSNL ( or MTNL in Mumbai and Delhi).
The state-owned provider offered an exciting new facility called CLIP – Caller Line Identification Presentation.  Since the first-generation keypad hand-sets had no display, you could, for a small additional charge, buy a small display unit which flashed the telephone number of an incoming call. What a luxury, to know who was calling! All you needed was to jot down a personal directory of the numbers of your friends and loved ones – now you could pick up their calls (and conversely reject calls from inconvenient sources).
By 2003, BSNL had built a numeric display into its handsets and   for Rs 300, you could buy a telephone receiver with CLIP built in. Soon, it became a free value-added service.
When mobile phones became affordable for the broad mass of Indians, the display of the incoming caller’s number, on the lines of the landline CLIP, was taken for granted as an essential service.|
If we created a private phone book on our mobile phones, the system helpfully  looked up our personal directory and displayed the name of the caller. And if you identified certain numbers as nuisance calls or “Unsolicited Commercial Communications” or UCC, an operating system like Android, allowed users to block such numbers.
 But like Oliver Twist we were hungry (for information) and ‘asked  for more’.   We wanted to know who was calling – even if the caller was not in our phone book.  
Coming of Truecaller
In 2009, a free Scandinavian app – Truecaller – became available. It crowdsourced information about the name attached to every mobile phone and – once you installed the app – displayed the name or company of the caller. It  was wrong or had no suggestion about half the time, but it was better than nothing.
Since 2020,  a made-in-India  option, Bharat Caller ID,supported by NASSCOM and StartupIndia  has been on offer.
Success rates were rarely spectacular since   in India at least, one could legally own up to 9 mobile phone numbers and – especially in families -- numbers for which the KYC or Know Your Customer details were provided by one member were often provided on phones to aged parents or young children and the like. And many small enterprises often used one or other of the personal mobile numbers of the founders, for official purposes.
There was no quick-fix solution to any of these data defects – not in a nation of    1.17 billion phones, almost all of them mobiles (December 2022 numbers).
TRAI Consultation Paper
Flash forward to November 29 2022. The Telecom Regulatory Authority of India (TRAI), in response to a direction from the Department of Telecommunications (DoT), issued a Consultation Paper on “Introduction of Calling Name Presentation (CNAP) in Telecommunication Networks.” (PDF here).
It mooted “the introduction of CNAP facility in telecommunication networks aims to empower subscribers to take an informed decision while receiving an incoming call, and to reduce the harassment of subscribers from unknown/ spam callers.”
It added: “Calling name identification presentation (CNIP) is a supplementary service offered to the called party which provides the name information associated with the calling party to the called party.”
To make this happen telecom providers would need to engage in a new level of  interdependence and cooperation,  sharing each other’s data bases and pushing the CNIP information through multiple interconnects.
Alternately – and the TRAI paper does not take a view on this – this will need the creation of a massive new central database in which the information provider by the purchaser of a new mobile phone SIM on the mandatory Customer Acquisition Form (CAF) is extracted and stored – for the use of all telephone service providers.
TRAI  provided time for all stakeholders to submit comments and counter comments to its proposal – these dates are extended to January 23 and February 6 respectively.
Stakeholder views
Almost every major stakeholder – the mobile service provider companies and their industry organizations and well as NGOs working in the subject area – has put its comments in the public domain – and these are divided between the technical complexity of implementing  CNIP and presenting a name with every incoming call,  and the ethical and privacy issues this  raises.
Reliance Jio points out that Caller ID is a feature of LTE and later generations (ie 4G and 5G) of mobile phones and will not work with 3G phones still widely in use (in fact the entire BSNL mobile network is yet to migrate to 4G). Additionally, the proposed Caller Name feature will not work on landline phones.
Jio also suggests that the name of the caller is his or her personal data and according to its understanding of the law, the caller’s consent is required before sharing it with the called person.
Vodafone-Idea (VI) agrees that this may conflict with the privacy concern of the calling party who may not want to flash his or her name on the screen of the called party.
Bharti Airtel suggests that the caller identity could be shared only in the case of  commercial users like telemarketers and not for  private callers, at least to start with.
The Internet and Mobile Association of India (IAMAI) highlights a particular concern of female subscribers: the service would display a woman phone caller’s name and number to every  party called without checking for her consent.
The Cellular Operator’s Association of India (COAI) representing the telecom service companies suggests that the caller name technology should not be made mandatory,  but should be left to individual providers to provide or not.
And the state-owned BSNL which professed to be for rolling out the caller name service, suggests that it could be an on-demand value added service, which subscribers could opt for if they chose – presumably at additional cost.
One very interested party in all this, is Truecaller, arguably the best known of the private caller ID apps. If the caller name is  made part of the mandated information to be provided in telecom providers in India (we are nowhere near there yet), it will lose its main USP at least in this country which also happens to be its biggest market.  It hints at ‘unintended adverse consequences’ for consumers of a compulsory caller name feature – possibly suggesting that this might add cost and fractional delay in putting through the call. It also highlights the large number of SIM cards which went under the radar of the official  ID check. 
True Caller’s seems to  be stressing the technical and  logistical challenges of a caller name identification and downplays the privacy aspects – natural since by already providing such information albeit crowdsourced and hence unauthenticated, it is in no position to cry ‘wolf’ about privacy violations.
Counter scenarios
In an opinion in Financial Express, Pradeep Mehta, Secretary-General of the consumer advocacy group,  Consumer Unity and Trusts Society ( CUTS International)  points to many scenarios where revealing the caller’s name might be counterproductive:
 “While well-intentioned, the potential positive and negative impacts of this proposal on consumers need to be thoroughly examined. For instance, there might be various scenarios wherein consumers may not wish to have their identities revealed on others’ devices. These could include calls by victims of domestic abuse, activists, journalists, auditors, investigators, watchdogs, whistle-blowers, or those bound by professional secrecy.”
“Also, consumers making one-off, innocuous or inquiry-related calls to e-commerce delivery personnel, cab aggregator drivers, booking agents, and other intermediaries and aggregators, may have no option but to give up their identity even before the call is picked up.”
“This one-size fits all approach, of displaying identity of all callers, bereft of nuances, may not necessarily be an optimal solution.”
Perhaps Mehta’s most compelling argument is this: ‘’Should scarce state capacity and public resources be invested to design regulatory intervention on an issue on which the industry is already making a lot of progress?”  Has a proper cost -benefit analysis been done?
When third party services are available which do much the same thing for free, is an egregious intervention of the state quite what is required at this moment, especially if any government mandate will involve additional costs for an industry not yet recovered from the huge upfront spectrum cost it has had to incur to roll out 5G?
A devil’s advocate might argue that when we acquired a land line telephone connection, our name and address appeared by default in the printed telephone directory (now a thing of the past).  Did anyone raise privacy concerns? If you -- a cinema star or similar celebrity -- wanted your telephone number to be ex-directory, you had to pay extra for the privilege.
But privacy has evolved as a concept over two decades, Today, when I fill in the Customer Acquisition Form when buying a mobile SIM, I provide a host of KYC or Know your Customer inputs, my name,  aadhaar number, residential address… but I authorized no one to  use this information as a database to be shared with thousands of other service providers and commercial interests without my consent.
Admittedly what TRAI has done is to float a balloon  on instructions of  the telecom ministry and watch which way  the winds of public opinion and stakeholder concerns take it. But till we have more compelling reasons to justify an intervention that on the face of it, leaves many  procedural and privacy issues, unaddressed, the move to tell every phone user, not just the number but the name of the caller, without checking on the wishes of caller or called, looks very much like a solution in search of a problem.

This article has appeared in Swarajya