The FCC is running a contest called "FCC Robocall Challenge". Details can be found at the following location: http://robocall.challenge.gov/. I have blogged about robocalls before. See: http://sigma5.blogspot.com/2012/02/rachel-from-cardholder-services.html for details. So this subject is near and dear to my heart. I think the FCC is slightly misguided. They think the winner should come up with a solution, presumably a gadget, that "should block robocalls". I think a proper solution consists of a number of components. Some of these components would be hardware. But other components would be processes or procedures. Here's my solution:
Telco component
All telcos (anyone providing dial tone and access to the international telephone network) must provide the following service, implemented by a code, to their customers. Someone on the contest web site suggested using “*111”. I will leave it to the experts to decide what actual code would be used. But when a customer receives an inappropriate call (e.g. a robocall) the customer will enter the code on his telephone keypad while the call is in progress. This will cause the telco to record and retain certain information about the call. Entering the code will also cause the call to be flagged as a “logged” call. The customer will also be able to enter the code up to five minutes after the call ends in normal circumstances. The window will expire immediately if the customer has not logged the call before making an outgoing call. Also, if a new call comes in within less than five minutes, the window will expire immediately if the customer does not enter the code to flag the old call as a "logged" call before connecting to receive the new call.
Telcos will maintain the information on logged calls for a minimum of a week (7 days). Then, if the customer “registers” the call within the one week period, the information will be retained for whatever period is appropriate. Once the information is transferred to e.g. an FCC database it can be deleted from the telco system.
The telco will collect and retain the following information when the call is logged:
- Nominal caller ID of the source.
- True source of the call.
- Nominal caller ID of the destination (customer).
- True destination of the call.
- Call start date/time.
- Call end date/time or call duration (Experts can decide which).
Note: A telephone call is a two way process. To work both the true source and the true destination must be known to the telephone system. This is the information that will be collected as the “true source” and “true destination”.
Note: Crime TV shows make reference to “LUDs”. If “LUDs” are a standard part of telephone infrastructure and the information in a LUD is equivalent to the information listed above then collecting a LUD for the call meets my requirements and no new special record type will be needed.
Customer component
This component is optional. But, if provided, it must operate as described.
First let’s consider a standard “land line”. For the moment let’s also assume that the line has a customer provided answering machine. The new component can be thought of as an “enhanced” answering machine that would replace the standard answering machine. The enhanced answering machine would require an Internet connection (e.g. Ethernet or WiFi connection with an IP address assigned to the device).
The enhanced answering machine would process calls that “go over to the answering machine” in the usual manner. But the enhanced answering machine would also speculatively record the first five minutes of all “live” incoming calls too. The telephone system started going digital in the 1960s. At that time a standard was established that converted the audio component of a conversation to a digital format. The digital data consisted of 56,000 bits of data per second of conversation. This is equivalent to 7,000 bytes of data. The enhanced answering machine will record the data in a standard format specified by experts that has a fidelity equivalent to the old 56,000 bits per second standard. Assuming no compression, a five minute recording would consume 2.1 million bytes of storage. This is well within the capability of inexpensive computer technology available today. Multi-Gigabyte thumb drives are readily available for about $10. If the standard included compression or other techniques, or the call lasted less than five minutes, the file could end up being much smaller. And the file should be encrypted using standard techniques for privacy reasons.
So the enhanced answering machine would speculatively record all incoming calls. If the call was not logged (see the above rules) then the recording would be silently discarded. Logged calls would be retained and a standard technique would be specified by the experts for transferring the recording to an Internet capable device (e.g. a computer). Vendors would be required to provide a minimum capability to record and retain one logged call at a time. The recording could be silently discarded after a week at the discretion of the device maker. The device maker could optionally provide the capability to retain more than one recording or retain it for longer than a week. The device maker would just have to spell out the actual capabilities over and above the minimum in the documentation for the device.
What is important here is the capability, not the specific hardware implementation. An enhanced answering machine is certainly an easy way to understand the required capability and feasible way to implement the capability in the case of a standard land line. But a lot of people now use smart phones. All the required capability can be implemented in a high end smart phone using software without requiring an external box or other supplemental hardware. Many people have an “answering machine” service provided by their telco using equipment not located on the customer premises. The telco could enhance their ”answering machine” service offering to provide equivalent capabilities. Or they could choose to not provide the additional capability. The only thing I require is that they be clear with their customers as to whether their “answering machine” service provides the described enhanced capability or not. If their offering did not provide the enhanced capability then customers would be free to decide whether they wanted to continue the telco provided service knowing that message recording would not be available to them or to instead go ahead and acquire an enhanced answering machine device to replace the telco offered service.
The registration process
We now have much more information available than before. We will now always have the logged information for all flagged calls. Where the additional capability exists (e.g. the customer has installed an enhanced answering machine) we also have a recording of the first five minutes of the incoming call.
A change would be made to the current process for registering a complaint with the FCC. Currently this is done through the FCC web site. The new process would be done through a telco web site or through a free down loadable app for smart phones or free app provided by telcos to their customers that would run on an Internet attached customer PC.
The telco would validate the identity of the customer e.g. by a log in process to their web site. In the case of a smart phone app, validation is automatic because the app runs on the customer smart phone and would only use data available on that smart phone. The registration/validation process should be simple in the case of a web site. And customers could log complaints to the FCC about their telco’s process if they did not like it.
Using the telco web site, smart phone app, etc. the customer would be able to see his recent logged calls. He would then be able to select one or more to “register” as a complaint with the FCC. The complaint information would be passed through to the FCC from the telco web site, app, etc. The detailed specifications I leave to experts. But I envision an implementation where the telco web site "front ends" for the FCC web site. The telco web site would be responsible for a "pass through" capability to pass the logged data and, if present, recording file, along to the FCC web site. The FCC would incorporate the logged data and, where it exists, the recording into the complaint. This is why the smart answering machine would need Internet access. The "Internet access" for this device could be restricted to the customer’s local LAN. The PC could pull the file from the smart answering machine and upload it into the complaint package. In the case of a smart phone or telco provided enhanced answering machine service the appropriate procedure would be used to include the recording in the complaint package. Timestamps would be used to match the correct recording to a logged call record.
FCC process
The FCC would now have much more information and much more reliable information for evaluating complaints. The FCC project is designed only to address inappropriate robocalls. So let me proceed along that path for a while. It is probably impossible to automatically identify robocalls. My recommendation is to not try to do it automatically. Use volunteers instead. The same registration process for the telco web site would be use to register volunteers with the FCC. The volunteers would listen to the recordings and evaluate manually whether the complaint was valid. They would not know the identity of any of the parties involved. All they would know was the type(s) of complaint alleged by the customer. Multiple volunteers would evaluate each recording and a super majority would be required to validate the complaint. The FCC would act accordingly in the case of a validated complaint.
Certainly this is a good process for dealing with robocalls but it is easily extended to handle other cases. This is done by giving the customer some options for characterizing the problem when a complaint is registered. One would be “robocall”. But another big problem is with live operators making illegal marketing calls (i.e. violating the “do not call” list).
I suggest that a rule be implemented that required all robocalls to include the name and a "contact" phone number for the organization making the robocall. The information must come in the first minute of the call. Customers could complain that the caller was not doing this or that he was providing bogus information. (It should be a serious crime to omit the information or provide bogus information). The same information would be required for “live operator” calls if the customer requests it. This permits a number of complaint categories:
- Company name omitted or bogus
- Contact phone number omitted or bogus.
- Contact number does not work (not answered or calls are not returned).
- Inappropriate contact (i.e. call not permitted by “do not call” exceptions).
- Illegal Robocall (marketing call rather than a e.g. "snow closure" informational call).
- Etc.
If the call contains misleading or bogus information the caller would first be gone after on this basis. If the contact name and phone number is correct then complaints would be aggregated by who is making them and the “use many separate numbers to originate the call from” trick would no longer work. This system would also catch spoofed “caller ID” numbers, which should be illegal, if it is not already.
Beyond the FCC
The FCC process for dealing with robocalls has been a failure from a customer perspective. It is possible that the FCC, even with this new capability, would not do an adequate job. So I recommend that individuals (or a class of individuals in a class action suit) be allowed to file a lawsuit in the situation where the FCC declines to prosecute. I believe that robocallers do not want to find themselves in a court room where they will be judged by a jury of citizens. This implied threat should allow the FCC to be much more effective than they currently are. Violators know that they are pretty toothless now.
This system can also be expanded to cover situations beyond robocall and “do not call” problems. An obvious example is harassing phone calls. Here the information would not go to the FCC but to law enforcement or the court system. In the worst case, the basic call information would be available. In the best case, a recording of the first five minutes of the call would also be available.
Basic threats e.g. “husband threatening to beat wife” situations could be dealt with directly. But other problems (e.g. “heavy breathing with caller not identified”) could also be addressed. The same third party validation system would be employed. This would filter out reverse harassment situations where the recipient is alleging harassment when none is actually present, at least not in the first five minutes of the call.
Analysis
Every indication is that the vast majority of robocalls originate from a small number of abusers. The above system seems slow and cumbersome but it will yield results that will actually solve the problem. It will take some time for the telcos to implement the logging process. It will be some time before customers have enhanced answering machine capability in large numbers. But it will get us to where we want to be in the end.
If the FCC contest yields what they say they are looking for (e.g. an inexpensive robocall filter device) it will be some time (years) before most customers have one. Likely the device will cost more than the enhanced answering machine device that is part of my proposal. So the aggregate cost of the FCC approach will be the same as or higher than the cost of my proposal and will probably take the same amount of time or longer to implement.
I see only one long term problem to my proposal. If my proposal is successful then robocalls and other similar telephone related problems will plummet. At that point the number of volunteer listeners will probably also plummet. But the need for listeners will plummet too. At that point it may be necessary to pay listeners to attract and maintain a sufficient number of them. If we get to this point perhaps some fine or fee will be needed to provide the money to pay the volunteers.
Finally, there are some areas I have not addressed. For instance:
- How is the volunteer pool managed (e.g. weeding out bad performers)?
- A lot can be done with just the registered complaints data, e.g. statistical analysis.
- Should the complaint database be published? (Of course!) How?
- How to deal with legitimate but unpopular callers (e.g. ethical collection agencies).
Sunday, October 21, 2012
Friday, October 19, 2012
Written Communication
I'm an old fart. When I was a kid the standard and pretty much only form of written communication was a hand written letter. Typewriters existed. But most of them were manual (hit a key and a series of levers would cause a letter to thwap into the paper). Electric typewriters existed. Here it was like power brakes on a car. You hit the key and electricity assisted the levers to thwap on the paper so you didn't have to hit the key so hard for the typewriter to work. But typewriters were for the office. Few homes had them. My home didn't have one.
So people like me were expected to occasionally hand write a letter to grandma or whoever. I was really bad at this for two reasons. The first one was practical. My handwriting was and still is horrible. I was taught "Palmer" penmanship in school but it didn't take. At some point I switched to printing rather than writing. But my printing, while better, was also pretty unreadable. The second problem was I was always stumped as to what to write. I now know that banal is just fine. Just natter on and everyone would be happy. But I was not a good natterer and I just never even figured out that that was what you did. So I was a bad boy. I can't remember writing even one letter as a kid. And just to give you an idea of how different that time was, a first class postage stamp was three cents.
In high school my mother insisted that I take typing. This was an improvement in that at least what I wrote would be legible. But I was also a terrible typist. A typical person can learn to type 30 - 80 words per minute. My top speed was about 15. And I was very inaccurate. If I tried to type even 15 words per minute I would make lots of mistakes. I remember that in one speed test lasting 15 seconds I made 12 mistakes. In spite of this my mother sent me off to college with a small typewriter, which was a good idea.
In terms of coming up with what to say, things got a little better. I had to take a series of English classes as a Freshman. After a couple of failed attempts to do something sensible I found that what worked for me was procrastination. If I waited until I barely had time to finish the composition then batted out whatever came to mind, I could complete the assignment. Surprisingly I got fairly good grades for these efforts.
Computers and I first met in college. And I found that I finally was in an environment that worked for me. I found I could quickly compose computer programs. And the "keypunch" machines of the time were like typewriters. Except there were tricks that allowed you to correct mistakes. And 15 words per minute was no impediment. While I was relatively quick, I wasn't quick enough to compose computer programs faster than I could type them in. So I was in hog heaven.
For many years I assumed that my compositional efforts would be restricted to computer software and I was OK with that. But technology marched on. First the CRT came along. CRT stands for Cathode Ray Tube. It is actually just the picture tube part of an old fashioned TV. But it came to be the nickname for a device consisting of a keyboard, CRT, and associated electronics. You typed on the keyboard and characters appeared on the screen. But now all you had to do was hit the "backspace" key to go back and correct errors. This was an improvement but initially it was only practical for using with computer software. So it became much easier for me to compose and update computer software but it was still impractical to apply these techniques to regular letters to regular people.
But an interesting thing happened as technology continued marching. I could pretend to write a program but then instead of putting it into the computer I could just print it out. Using this trick I could compose something like a letter. And I did so. I composed and printed a number of letters about some practice or project having to do with work and passed them along to the computer center manager. He told me he liked them and found the information in them useful. He encouraged me to write more of them. This was the first time it occurred to me that I might have something to say.
Technology marched on and E-Mail evolved. This was clearly a potential substitute for the hand written letter. Initially it as only a little better than the "write a computer program that is really a letter and then print it out" system I had been using. And E-Mail systems only allowed you to send a letter to someone who had a CRT that was hooked up to the same computer as your CRT. So it was only good for sending E-Mail to other people who worked in the same building or perhaps the same company. But eventually E-Mail systems started connecting to each other and finally through the Internet to anyone who had a computer. And by this time lots of people had a computer.
I had finally arrived. I could communicate via E-Mail. I could type rather than write. So the result was legible. I had decided by this time that I had something to say. Mostly it was about work or technical stuff but that beat having nothing to say at all. I am still not that good at nattering but I am better than I used to be. And E-Mail systems came with spell check. I have always been a bad speller. Being a bad speller then adding a lot of typing mistakes on top makes for a pretty bad situation. But it was as good as it was going to get for me.
But technology continued to march on. E-Mail is now "so last year" or "last decade" or whatever. (See, there is an entirely legitimate use for the much maligned "whatever"). The currently popular methods of communication are Facebook and Twitter. I have neither a Facebook account nor a Twitter account. To be a proper Facebook user you are supposed to post pictures and do all kinds of other stuff I am bad at. Twitter is all about the famous "140 character limit". A lot of people have found a lot of very good things to say in 140 characters. And Twitter allows you to link to something like a picture, a blog post, or something else that doesn't fit into 140 characters. But I am a long form kind of guy. Most of the time I want to say something that will take a lot more than 140 characters to say. Facebook is a great picture sharing service. And Twitter is a great way to broadcast headlines. But I am not very good at either of those things. So I have been passed by.
But wait, it's worse. Most people still have one or more E-Mail accounts. So I can pretty much communicate to anyone I want by sending an E-Mail. But I have noticed something. A lot of people manage their E-Mail accounts using a smart phone. Smart phones have sucky keyboards. So people keep their responses short. And I find that sometimes they don't scroll down or whatever (because it's hard to do on that small screen) and they miss part of what's in my message. So I find that E-Mail is becoming more and more Twitterized. It is becoming just another home for "headline" messages.
"What a world. What a world."
BTW, that's what The Wicked Witch of the West said while she was melting in the 1939 MGM version of "The Wizard of Oz".
So people like me were expected to occasionally hand write a letter to grandma or whoever. I was really bad at this for two reasons. The first one was practical. My handwriting was and still is horrible. I was taught "Palmer" penmanship in school but it didn't take. At some point I switched to printing rather than writing. But my printing, while better, was also pretty unreadable. The second problem was I was always stumped as to what to write. I now know that banal is just fine. Just natter on and everyone would be happy. But I was not a good natterer and I just never even figured out that that was what you did. So I was a bad boy. I can't remember writing even one letter as a kid. And just to give you an idea of how different that time was, a first class postage stamp was three cents.
In high school my mother insisted that I take typing. This was an improvement in that at least what I wrote would be legible. But I was also a terrible typist. A typical person can learn to type 30 - 80 words per minute. My top speed was about 15. And I was very inaccurate. If I tried to type even 15 words per minute I would make lots of mistakes. I remember that in one speed test lasting 15 seconds I made 12 mistakes. In spite of this my mother sent me off to college with a small typewriter, which was a good idea.
In terms of coming up with what to say, things got a little better. I had to take a series of English classes as a Freshman. After a couple of failed attempts to do something sensible I found that what worked for me was procrastination. If I waited until I barely had time to finish the composition then batted out whatever came to mind, I could complete the assignment. Surprisingly I got fairly good grades for these efforts.
Computers and I first met in college. And I found that I finally was in an environment that worked for me. I found I could quickly compose computer programs. And the "keypunch" machines of the time were like typewriters. Except there were tricks that allowed you to correct mistakes. And 15 words per minute was no impediment. While I was relatively quick, I wasn't quick enough to compose computer programs faster than I could type them in. So I was in hog heaven.
For many years I assumed that my compositional efforts would be restricted to computer software and I was OK with that. But technology marched on. First the CRT came along. CRT stands for Cathode Ray Tube. It is actually just the picture tube part of an old fashioned TV. But it came to be the nickname for a device consisting of a keyboard, CRT, and associated electronics. You typed on the keyboard and characters appeared on the screen. But now all you had to do was hit the "backspace" key to go back and correct errors. This was an improvement but initially it was only practical for using with computer software. So it became much easier for me to compose and update computer software but it was still impractical to apply these techniques to regular letters to regular people.
But an interesting thing happened as technology continued marching. I could pretend to write a program but then instead of putting it into the computer I could just print it out. Using this trick I could compose something like a letter. And I did so. I composed and printed a number of letters about some practice or project having to do with work and passed them along to the computer center manager. He told me he liked them and found the information in them useful. He encouraged me to write more of them. This was the first time it occurred to me that I might have something to say.
Technology marched on and E-Mail evolved. This was clearly a potential substitute for the hand written letter. Initially it as only a little better than the "write a computer program that is really a letter and then print it out" system I had been using. And E-Mail systems only allowed you to send a letter to someone who had a CRT that was hooked up to the same computer as your CRT. So it was only good for sending E-Mail to other people who worked in the same building or perhaps the same company. But eventually E-Mail systems started connecting to each other and finally through the Internet to anyone who had a computer. And by this time lots of people had a computer.
I had finally arrived. I could communicate via E-Mail. I could type rather than write. So the result was legible. I had decided by this time that I had something to say. Mostly it was about work or technical stuff but that beat having nothing to say at all. I am still not that good at nattering but I am better than I used to be. And E-Mail systems came with spell check. I have always been a bad speller. Being a bad speller then adding a lot of typing mistakes on top makes for a pretty bad situation. But it was as good as it was going to get for me.
But technology continued to march on. E-Mail is now "so last year" or "last decade" or whatever. (See, there is an entirely legitimate use for the much maligned "whatever"). The currently popular methods of communication are Facebook and Twitter. I have neither a Facebook account nor a Twitter account. To be a proper Facebook user you are supposed to post pictures and do all kinds of other stuff I am bad at. Twitter is all about the famous "140 character limit". A lot of people have found a lot of very good things to say in 140 characters. And Twitter allows you to link to something like a picture, a blog post, or something else that doesn't fit into 140 characters. But I am a long form kind of guy. Most of the time I want to say something that will take a lot more than 140 characters to say. Facebook is a great picture sharing service. And Twitter is a great way to broadcast headlines. But I am not very good at either of those things. So I have been passed by.
But wait, it's worse. Most people still have one or more E-Mail accounts. So I can pretty much communicate to anyone I want by sending an E-Mail. But I have noticed something. A lot of people manage their E-Mail accounts using a smart phone. Smart phones have sucky keyboards. So people keep their responses short. And I find that sometimes they don't scroll down or whatever (because it's hard to do on that small screen) and they miss part of what's in my message. So I find that E-Mail is becoming more and more Twitterized. It is becoming just another home for "headline" messages.
"What a world. What a world."
BTW, that's what The Wicked Witch of the West said while she was melting in the 1939 MGM version of "The Wizard of Oz".
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