[huridocs-tech] ENUM technology raises public policy concerns

CDT POLICY POST Volume 9, Number 9, April 28, 2003

A Briefing On Public Policy Issues Affecting Civil Liberties Online
from
The Center For Democracy and Technology

(1) CDT Report Analyzes Public Policy Concerns About ENUM Technology
(2) What is ENUM, and Has It Been Deployed Yet?
(3) Policy Issues Raised by ENUM
(4) Recommendations for ENUM Implementations

-------------------------------------------------------------
(1) CDT Report Analyzes Public Policy Concerns About ENUM Technology

ENUM, a technology protocol that may provide a critical tool in the more
widespread adoption of  "voice over the Internet" services, also poses 
risks to
privacy.

CDT's Standards, Technology & Policy Project has issued a report analyzing a
range of privacy and other public policy concerns raised by the ENUM 
protocol.
The report sets out detailed policy recommendations that should be followed by
national governments and service providers in any implementation of ENUM.

"ENUM:  Mapping Telephone Numbers onto the Internet -- Potential Benefits With
Public Policy Risks" is available at http://www.cdt.org/standards/enum/.

Additional information about CDT's Standards Project is available at
http://www.cdt.org/standards/.

-------------------------------------------------------------
(2) What is ENUM and Has it Been Deployed Yet?

ENUM is a protocol that allows the translation of normal telephone numbers 
into a
format that can be used to store and retrieve Internet addressing 
information, which
can in turn be used to route communications over the Internet.  With ENUM and
"Voice over Internet Protocol" ("VoIP") technology, an increasingly amount 
of voice
communications can be carried over the Internet instead of over the 
traditional
telephone network.  Initially, ENUM is likely to be deployed by 
corporations and
other large institutions that seek to reduce their use of traditional 
telephone
services (especially international and other long distance service).  This 
technology
has the potential to allow users -- corporations and individuals -- to save 
money
and increase the choices they can exercise in their communications.

ENUM will facilitate the routing of telephone calls over the Internet, in a 
manner that
is seamless to the end users.  To place a call with ENUM, (1) a person dials a
standard phone number on a normal telephone (or on a telephone-like device
connected to a computer), (2) the computer or telephone system uses ENUM to
check if the called number can be reached over the Internet using VoIP 
technology,
(3) if the number can be reached, a VoIP call is initiated, and (4) if the 
number
cannot be reached over the Internet, the call is routed to the traditional 
telephone
network.

ENUM-compliant technologies and implementations are still in the development
and testing stages.  A number of nations around the world have initiated 
formal
ENUM "test bed" implementations.  The United States Department of Commerce
has endorsed the U.S.'s participation in ENUM, and set out a series of 
guidelines to
be met before formal tests or government-sanctioned implementations can
proceed.  Commercial deployment of ENUM services is likely to take place by 
the
end of 2004.

-------------------------------------------------------------
(3) Policy Issues Raised by ENUM

ENUM's potential benefits also bring risks in terms of privacy and other 
public
policy concerns.  The simplest implementation of ENUM envisions that 
individuals'
personal contact information (such as telephone numbers and e-mail addresses)
will be stored in special records located in the Domain Name System (or 
DNS) of
the global Internet.  Because the DNS is publicly available, ENUM could
significantly compromise the privacy of its users, and could lead to 
additional spam
and other problems.

A more complex use of ENUM (in conjunction with a device called a "proxy 
server"),
however, offers the opportunity to gain the benefits of ENUM without 
sacrificing
control over personal information.  To minimize the potential harmful 
effect of
ENUM on privacy, it is vital that this second, more complex approach to 
ENUM be
permitted and available in the marketplace.

Other important issues turn, for example, on (a) how much information 
individuals
or companies will be required to provide in order to take advantage of 
ENUM, and
(b) how much of that information will be revealed in a public database 
(similar to
the "whois" database which reveals information about domain name holders).Â

In a different vein, ENUM raises a range of policy issues about how closely 
"ENUM
numbers" should be tied to existing traditional telephone numbers.

One critical aspect of the global public policy issues surrounding ENUM is 
the fact
that ENUM will, for the most part, be implemented within each country by the
telephone authorities or companies that operate within that country.  Thus, 
many
critical decisions (for example, about how much information will be 
required to
obtain an ENUM number) will be made on a country-by-country basis.  It is 
critical
that within each country, the relevant telephone authorities must closely 
consult
with the public interest and civil society sector, the communications 
industry, and
the computer industry.

-------------------------------------------------------------
(4) Recommendations for ENUM Implementations

To ensure that users can take advantage of ENUM without sacrificing 
privacy, any
implementation of ENUM should follow a number of guidelines to ensure that 
there
is a diversity of ENUM service providers and that those providers will be 
able to
offer privacy-protecting ENUM options.  CDT's report on ENUM details 14 
specific
policy recommendations.  Among the specific recommendations are:

- At no time should any ENUM record be created without the express consent of
   the individual or entity that subscribes to the corresponding telephone 
number
   on the traditional telephone network.  An ENUM user should explicitly 
"opt-in"
   to the ENUM service.

- No publicly accessible whois-like database of ENUM subscribers should be
   created.

- Prospective ENUM users should receive clear notice of the privacy risks
   and consequences of using ENUM.

- ENUM policy within a country should be set in close consultation with the
   public interest and civil society sector, the communications industry, and
   the Internet industry.

CDT's report on ENUM also provides a bibliography of references and links to
ENUM resources and analyses.

-------------------------------------------------------------
Detailed information about online civil liberties issues may be found at
http://www.cdt.org/.

This document may be redistributed freely in full or linked to
http://www.cdt.org/publications/pp_9.09.shtml.

Excerpts may be re-posted with prior permission of ari@cdt.org

Policy Post 9.09.  Copyright 2003 Center for Democracy and Technology

--
Michael Clark, Grassroots Webmaster
mclark@cdt.org
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Center for Democracy and Technology
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Washington, DC 20006
http://www.cdt.org/
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fax: 202-637-0968


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