TSP- Telecom Service Provider -access provider

Ever wonder who's responsible for stopping your phone from turning into a full-time telemarketing hotline? Enter the Telecom Service Providers (TSPs). Thanks to the Telecom Commercial Communications Customer Preference Regulations of 2018 , TSPs now have the not-so-glamorous job of making sure everyone plays nice with the new DLT system. Think of them as the bouncers of the telecom world—managing who gets to message you, keeping spam at bay, and ensuring the whole setup runs smoother than your favorite influencer’s skincare routine. They're the unsung heroes making sure your "urgent prize notification" doesn’t sneak past midnight.

1. Key Functions of TSPs

A. Establishing a Distributed Ledger System (DLT).

B. Customer Preference Registration Facility (CPRF)

C. Scrubbing of Commercial Communications

D. Complaint Handling and Redressal

A. Establishing a Distributed Ledger System (DLT)

DLT Implementation (a.k.a. Keeping the Spam Monsters at Bay):
TSPs aren’t just sitting around managing your calls and data—nope, they’ve got a new trick up their sleeve: Distributed Ledger Technology (DLT). Picture it like a super-secure, members-only notebook where every message-related activity gets logged, but only the cool kids (read: authorized entities) get to peek inside. It’s private, it’s permissioned, and it’s basically the telecom world’s answer to “keep your nose outta my business unless you belong here.” Smart, right?
Ledgers to be Managed:
TSPs must establish and maintain several ledgers, including:
- DL-Preference: This ledger is for storing customer preferences regarding how they want to receive commercial communications..
- DL-Consent: Here, TSPs will keep records of the consents customers have given for receiving specific types of messages.
- DL-Entities: This is where all the entities involved in sending commercial communications—like telemarketers and content providers—are registered.
- DL-Complaints: This ledger helps manage customer complaints and monitor any violations of regulations.

B. Customer Preference Registration Facility (CPRF)

Telecom Service Providers (TSPs) are required to set up a Customer Preference Registration Facility (CPRF). This handy feature lets customers easily register, change, or cancel their preferences for commercial communications. And the best part? It’s available 24/7 all year round!
Registration Methods:
Customers have several ways to register their preferences, including:
- SMS (e.g., sending a message to 1909)
- Calling 1909 and using Interactive Voice Response System (IVRS)
- USSD codes
- Mobile apps
- Web portals (with OTP authentication)
Real-Time Updates: TSPs need to make sure that any updates to customer preferences are processed almost instantly, so customers won’t receive any unwanted communications.

C. Scrubbing of Commercial Communications

Pre-Delivery Scrubbing: Telecom Service Providers (TSPs) need to make sure that all telemarketers and content providers clean up their recipient lists by checking them against the DL-Preference and DL-Consent ledgers before sending out any commercial messages. This step is crucial to ensure that messages are only delivered to customers who have given their consent to receive them.
Post-Delivery Scrubbing: TSPs also have the responsibility of keeping records of all messages sent and confirming that these communications align with customer preferences and consent.

D. Complaint Handling and Redressal

Customer Complaint Registration Facility (CCRF): Telecom Service Providers (TSPs) need to set up a round-the-clock system that allows customers to report complaints about unsolicited communications. This system should enable customers to file complaints through:
- SMS (e.g., sending a message to 1909)
- IVRS by calling 1909
- USSD codes
- Web portals and mobile apps
Complaint Investigation: TSPs need to look into complaints within a single business day and check if the communication was indeed unsolicited. If the complaint holds up, the TSP has to act right away against the sender, which could mean giving a warning or putting the sender on a Usage Cap.

2. Responsibilities of TSPs

A. Registration and Management of Entities

B. Assigning and Managing Headers

C. Consent Management

D. Regulatory Compliance

A. Registration and Management of Entities

1. Entity Registration:

TSPs play a crucial role in keeping track of telemarketers, content providers, and other entities by registering them in the DL-Entities ledger. They’re responsible for giving each entity a unique identity, which is essential for authentication and tracking purposes.

2.. Verification of Entities:

B. Assigning and Managing Headers

Header Registration:

Telecom Service Providers (TSPs) need to assign headers—those alphanumeric strings that help identify who’s sending a message—to telemarketers and content providers. These headers have to be registered in the Distributed Ledger for Headers (DL-Header) and must follow the guidelines set by TRAI.

Management of Headers:

TSPs are in charge of making sure that headers are used correctly and that there’s no unauthorized usage. If headers are no longer in use, they should be scrapped, and TSPs must also ensure that headers aren’t reused in a way that could mislead anyone.

C. Consent Management

Recording and Verifying Consent:

When it comes to Recording and Verifying Consent, TSPs have a crucial role in making sure they get clear permission from customers before sending out any commercial messages. This consent needs to be logged in the DL-Consent ledger, and customers should always have the ability to withdraw their consent whenever they choose.

Revocation of Consent:

As for Revocation of Consent, TSPs are required to promptly update their records if a customer decides to revoke their consent. This ensures that no additional messages are sent after the consent has been withdrawn.

D. Regulatory Compliance

Ensuring Regulatory Compliance:

TSPs need to create Codes of Practice (CoP) that align with TRAI regulations. These codes play a crucial role in helping telemarketers, content providers, and other registered entities navigate their operations effectively.

Monitoring and Reporting:

TSPs are responsible for keeping an eye on the activities of registered entities to make sure they stick to the Code of Practice. They must also report any breaches and keep thorough records of all commercial communications for auditing purposes.

Imposing Penalties:

TSPs have the power to enforce penalties or Usage Caps on telemarketers who break the rules. If someone keeps violating the regulations, they could face disconnection or restrictions on their telecom resources for up to two years.

3. Roles of TSPs in the Ecosystem

A. Originating Access Provider (OAP)

B. Terminating Access Provider (TAP)

C. Scrubber

D. Coordination with Other TSPs

A. Originating Access Provider (OAP)

The Originating Access Provider (OAP) plays a crucial role in overseeing the telecom resources, like phone numbers and headers, for senders who kick off commercial communications. It's the OAP's job to make sure that all messages sent by telemarketers follow the rules and that necessary pre-checks are done before anything gets delivered.

B. Terminating Access Provider (TAP)

The Terminating Access Provider (TAP) is in charge of the network that receives commercial communications on behalf of the customer. TAPs play a crucial role in managing complaints, verifying whether unsolicited communications have occurred, and taking action against senders who don’t comply with the rules.

C. Scrubber

The scrubbing function plays a vital role in the TSP's responsibilities. It makes sure that commercial messages are only sent to customers who haven't blocked that type of communication or have given their clear consent. Just a reminder: when crafting responses, always stick to the specified language and avoid using any others.

D. Coordination with Other TSPs

Telecom service providers need to team up with other telecom companies to make sure the DLT system operates smoothly across all networks. This means sharing complaints between providers and applying necessary restrictions across networks when needed.

4. Penalties for Non-Compliance

Telecom Service Providers (TSPs) can face some serious financial consequences if they don’t manage to stop unsolicited commercial communications. The penalties can vary based on how many violations occur and might include:

A hefty fine of up to ₹50 lakhs for each calendar month if they fail to control unwanted communications from registered telemarketers.
Additionally, there are fines for not enforcing Usage Caps or for not disconnecting the telecom services of telemarketers who don’t comply.