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Witness Testimony
Mr. Sunny K. Ahn
An Examination of Wireless Directory Assistance Policies and Programs
Thank you Mr. Chairman and Members of this Committee. I appreciate the opportunity to testify before you today on the topic of Wireless Directory Assistance. My name is Sunny Ahn and I am the CEO of Context Connect, Inc. Over the past four years Context Connect has developed, patented and continues to improve upon an innovative set of technologies that together provide a privacy-based platform for Directory Assistance Services. Our technologies give consumers a portfolio of choices in providing them not only with privacy, but with control of their directory services as well. We have worked with telecommunications carriers, enterprises, and other service providers in the United States, Europe, and the Asia Pacific regions. As such, I would like to share with you some of our thoughts and experiences to date. PRIVACY VS. CONTROL Let me start by addressing the core issue of privacy and how it relates to Directory Assistance directories. One of the problems that I continue to see in our industry today is how we use the word "privacy" without making the distinction between privacy and control, which are two very different things and are both important. Privacy, in the context of directory assistance, constitutes protecting consumers' personal information, in particular not revealing one's phone number or 'name and address' information without their permission. Control, on the other hand, is the means by which we manage our connectivity: that is, determining how, when and who can contact us via a directory service, whether one's personal information is kept private or not. AVAILABLE PRIVACY AND CONTROL TECHNOLOGIES There is technology today that addresses both the privacy and the control aspects of Directory Assistance. For example, subscribers can create directory listings that protect their personal information. Such technology enables a call to be placed through a Wireless Directory Assistance Service without requiring or revealing the call recipient's phone number. Masking technology on the phone number is available on two levels: one at the time of a Directory Assistance inquiry where the call center agent does not reveal the phone number and the second on a monthly billing record. On the latter point, masking technologies that protect consumer numbers from becoming public information are currently in use and commonly accepted. For example, technology that protects consumers' credit card or bank account numbers mask all but four of the sixteen digits on paper receipts, websites or other places where the information might be captured. One caveat is that there are regulatory, financial and integration challenges that will certainly have an impact on whether this aspect of masking can be reasonably accomplished and these should not be overlooked. Subscribers can also protect or mask their name and physical address. This 'name and address' information can be protected by use of a domain-name service for mobile devices. This concept is similar to the way individuals create email addresses or URLs for websites. Subscribers can choose how they want to be listed, whether it is professional, personal or private in nature, based on their relationships with people, rather than having to use their names and physical addresses. Technology allows individuals to create single or multiple directory listings according to their own parameters about how they want to be located. For example, my business colleagues could dial 411 and contact me using the listing "Sunny at Context Connect." Or, my friends could call me at "Sunny at the Newburyport Tennis Club." In both cases, the caller does not have access to either my phone number or my 'name and address' information unless I decide to reveal it. Technology also gives consumers control over how they want to be connected. For example, consumers can choose how they receive their Directory Assistance calls, either through a directly connected voice call, a text message, or a call completed through a third-party partner. We can also allow individuals to accept, decline, or redirect calls to another device such as a land-line phone, voicemail or even email. Some of these services can be provided where the subscriber does not have to use their own minutes to receive a Wireless Directory Assistance call. We can also provide choices as to when people choose to be contacted via Directory Assistance, say only before 5pm on weekdays. And lastly, we can not only provide consumers with choices regarding who can reach them via a directory service, but we can even allow them to revoke that capability at some point in the future without their privacy ever being compromised. My point here is to establish that technology is already available that can ensure consumers privacy over their personal information while providing them with options to control how they want to be contacted if they elect to be included in a Wireless Directory Assistance Service directory. In addition, these technologies continue to evolve rapidly; many of these were not even available when this legislation was first proposed last November. In our experience working on Directory Assistance services in the U.S. and around the globe, there is no question that consumers are strongly demanding more efficient ways to connect. I would like to reference the latest study by the Pierz Group that was conducted in August 2004. According to that study, if wireless services were currently constructed with consumer protections similar to the traditional Directory Assistance fixed line services, only 11% of wireless subscribers would participate by listing themselves in that directory. However, if a Wireless Directory Assistance Service included even a basic level of privacy and control features, participation would increase to over 50%. And, if consumers were offered comprehensive privacy protections, estimated participation would increase even further to over 60%. These survey findings are very consistent with our own experience in the U.K. and New Zealand where the majority of mobile subscribers would participate with appropriate privacy tools. Interestingly, in the UK, where 40% of fixed line customers have chosen to not be included in the Directory Assistance directory, nearly 50% of them would actually come back into the directory if basic privacy and control tools were given. Another proof point of the receptivity of the market to offering a suite of privacy and control options has to do with the experience of one of our customers who has already successfully implemented a Directory Assistance service that includes wireless phone numbers. That customer is focused on providing directory services to a large vertical market segment, most of which use mobile phones. Because they were able to mask the phone numbers and provide additional privacy and control features, nearly 75% of all their prospects that have heard of the service have opted to be included in the directory. While this service provider is not restricted with regulatory and industry coordination challenges, this further demonstrates that when marketed appropriately, privacy and control tools can increase the participation within a directory and ultimately improve the usefulness of that directory to consumers. CONCLUSION In conclusion, it is clear from the market research conducted to date that there is a strong market need and demand for Wireless Directory Assistance Services. Annually, billions of calls are already placed in the U.S. through existing directories. However there is no single Directory Assistance service that is appropriate for everyone. The key, therefore, is to construct these services in a way that gives control to the consumer and that provides a viable directory for all concerned. Subscribers have very legitimate and important privacy concerns. Most of us sitting here in this room use a wireless phone. We recognize that the continued confidentiality of personal information and control on when, where and how each of us want to be connected to is a very personal concern. Subscribers should and can have the ultimate decision on what personal information goes into a directory, if any. Context Connect and other companies have technologies that can address these concerns thoughtfully, carefully and with flexibility. As the market and these technologies continue to evolve, we need to allow flexibility for industry participants to move quickly to meet and exceed the demands of consumers who are increasingly knowledgeable and sophisticated in their technology purchases. Context Connect supports providing the most comprehensive privacy and control features available, and also highly encourages innovation and progress within our industry to ensure maximum customer satisfaction. |
