Hong Kong Call Centre Association
August 6th, 2014
Response to The Privacy Commissioner Urging the Administration to Expand the Do-not-call Registers to Include Person-to-person Calls
The Hong Kong Call Centre Association has received and read the press release and the survey report issued by the Privacy Commissioner on August 5th.
The Association would like to express the following comments:
1. The press release brings to the forefront a number of important issues which the Hong Kong Call Centre Association has identified previously. Foremost amongst these is the number of rogue operators making cold-calls (called numbers generated by computer without personal data of the called party) to the public from offshore that mask their true identity using technology. This will not stop with The Commissioner’s requested Do-not-Call (D-n-C) listing.
2. Ofcom, the independent regulator and competition authority for the United Kingdom’s communications industries, together with the Information Commissioner’s Office (ICO), recently (July 24th, 2014) published research into their findings on The Effectiveness of the Telephone Preference System (TPS), or their version of aDo-not-Call listing. The inconvenient truth is that, of those who have registered for the United Kingdom’s version ofthe D-n-C list, there has only been a 35% reduction in the number of unsolicited calls. The reason for this is likely the number of offshore organisations that continue to operate with impunity, as they are difficult to track.
3. The Hong Kong Call Centre Association contends that its members support and operate within the Personal Data (Privacy) (Amendment) Ordinance 2012 and the strict requirements that were introduced in 2013. They do so because it makes good business sense to reflect a consumer’s wish to opt out at whatever stage of their relationship.
In fact, to address the concerns of the population at large, the Hong Kong Call Centre Association took the lead to develop a Code of Practice (CoP) together with key telemarketing companies within Hong Kong. With the support from the Office of the Communications Authority (OFCA), the CoP has been effective since 1 July 2010. A CoP Certification mechanism with an independent body conducting audit has been in place since 2011. As part of our pledge, key members from within the industry report their figures including complaints and opt-outs received from our member’s customers. This information is reported twice annually to Commence and Economic Development Bureau (CEDB)
4. We are concernedabout a blanket Do-not-Call (DNC) registry on Person to Person telemarketingcalls, because it won’t stop the “rogue operators” from contacting Hong Kongcitizens. It will, however, impact tensof thousands of people who are gainfully employed using the phone tolegitimately speak with business prospects.
In closing, we suggest that The Privacy Commissioner concentrate his immediate efforts and considerable powers towards identifying the offshore operators that are causing the vast majority of these unsolicited calls with or without personal data. We would be happy to work with The Privacy Commissioner and CEDB towards this end.
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About the HK CCA
The HK Call Centre Association(www.hkcca.com) is a non-profit organisation that has a mission to help local businesses improve their contact centres and customer service by deploying the best management practices and latest technologies. The HK CCA has grown to include over 450 individuals and corporate members in both Hong Kong and Southern China and supports its members through annual benchmarking studies, site visits, awards competitions, training seminars, speakers and many social events.
Mr. Rayland Chan firstname.lastname@example.org
Tel: +852 3966 2852