There were very few reply comments submitted last week for the CRTC’s consultation on delegation of its investigative powers for the telemarketing rules.
Only four groups show up on the CRTC’s website as having sent in reply comments.
The Canadian Marketing Association (CMA) warns that the registry of telemarketing agencies could rival Canada’s infamous gun registry:
to attempt to identify, register and charge fees to the hundreds of thousands of companies that engage in telemarketing will be a controversial administrative nightmare rivalling that of the gun registry.
Ottawa can be a little touchy about the subject of large government administered registration databases.
The phone companies comments acknowledge that there are approximately 80,000 registered charities alone, let alone the countless – but soon to be counted, if the CRTC has its way – number of clubs, school groups, church organizations and small businesses that make calls of any kind dealing with selling something or in some way involving money. Not only will these groups need to register once, but the telemarketer registry records will certainly need to be kept up-to-date, providing the “telemarketing police” with contact information of this year’s head of the grade 8 class trip chocolate bar sales campaign.
Maybe when future school trips come to Ottawa, the tours will include a visit to the Unsolicited Telemarketing Rules investigator’s headquarters. Each kid can come home with a souvenir whistle.
Considering the challenge that the local service contribution administrator has in keeping its records up to date, or the CRTC with its international phone licenses, the CMA is likely not far off in its gun registry analogy for an administrative nightmare associated with this broadly defined telemarketer registry database.
CMA’s comments suggests that the rationale for the registration process with an independent investigator appears to be for the CRTC to avoid conducting its own investigations funded by the phone companies through the consolidated revenue fund. That might be a reasonable expectation since the phone companies are the people profiting from the sale of communications services to telemarketers – whether the calls are exempt from the DNCL or not.
CMA is rightly concerned about its members once again being caught in the cross fire. After all, the fact that a telemarketer joins CMA is a sign that it wants to follow the rules. CMA’s members aren’t the concern for most of us – it is the calls from commercial telemarketers who aren’t members of CMA.
Update [October 15, 12:20 pm]
Today’s National Post includes a story about government red tape burying small business. It makes me wonder why associations representing small and independent businesses didn’t weigh in on this CRTC file.
Is the registry going to be consistent with the objective to reduce the paper burden 20% by November, 2008 from Secretary of State responsible for Small Business & Tourism, Diane Ablonczy. “Key departments and agencies must actually start a count of their requirements being placed on businesses.”