Introduction

The Commission for Complaints for Telecom-television Services (“CCTS”) is Canada’s national and independent organization dedicated to resolving customer complaints^[1] about telecommunications and television distribution services. As of December 31, 2021, there are 301 service providers, represented by 426 customer-facing brands that participate in the CCTS (referred to as Participating Service Providers or “PSPs”).

As participants in the CCTS, PSPs are required to carry out the requirements of the CCTS’ PSP Public Awareness Plan,^[2] comply with the Procedural Code, and meet their financial obligations (e.g. disclose their retail revenues and pay CCTS fees). The CCTS actively monitors compliance with these participation requirements and engages with non-compliant PSPs to bring them into compliance.

During the CRTC’s last review of the CCTS in 2016, the CRTC stated its expectation^[3] that the CCTS:

• more actively monitor and encourage PSP compliance with their obligations; and
• enforce these obligations using the CCTS’ available tools such as publishing in a prominent manner the names of non-compliant PSPs.

Given these CRTC directives, the CCTS laid the groundwork to formally monitor and track compliance and enforcement in 2017, which included amending our constating documents and developing our internal processes for compliance.  We informed PSPs that we would begin monitoring, tracking and reporting on compliance with the Procedural Code, Public Awareness Plan and financial requirements (e.g. disclosing retail revenues and paying CCTS invoices).

In January 2018, the CCTS formally launched the compliance monitoring and enforcement program and held an information session for PSPs.  The CCTS began tracking and identifying failures to comply with participation requirements and started engaging with PSPs about compliance issues.

In general, when we identify a non-compliance issue, we work with the PSP on an individual basis to explain the requirements, our expectations, and how the PSP can become compliant.  We find that many PSPs want to work with us to rectify any issues of non-compliance.  In some circumstances, we invest considerable time and effort to educate a PSP and work with it to bring it into compliance.  In the rare circumstances when the CCTS exhausts all its tools and the PSP fails to comply with major or long-standing non-compliance issues, the CCTS terminates the service provider as a participant in the CCTS.^[4] Since the CRTC mandates participation by the provider, we refer the matter to the CRTC for further action. The CCTS does not resort to this enforcement measure until after we have made every effort to get a PSP to rectify its major non-compliance without success.

Each year, the CCTS publishes an annual Compliance Monitoring Report discussing the activities and issues we observed in the preceding year.  This report also highlights the enforcement measures taken and publicly identifies the names of service providers who failed to join the CCTS when required to do so, PSPs with major non-compliance issues, and any PSPs whose participation was terminated.

The CCTS strives to continuously improve compliance activities based on feedback from our stakeholders, including the PSPs, CRTC and consumers.  We prioritize communicating with PSPs on an individual basis to increase PSPs’ understanding of their participation requirements and to bring non-compliant PSPs into compliance.  As a result, our compliance efforts can take a considerable amount of time and effort.