How many exceptions to number plan have been granted

Rev Adrian Kennard made this Freedom of Information request to Office of Communications

This request has been closed to new correspondence. Contact us if you think it should be reopened.

The request was successful.

Rev Adrian Kennard

Dear Office of Communications,

Please can you advise in how many cases have OFCOM granted telcos exceptions to the National Numbering Plan rules relating to 07 mobile numbering to allow each of the following (which are otherwise prohibited by those rules).

1. Allowing calls to be terminated on voicemail
2. Allowing calls to be diverted to a non mobile number
3. Allowing calls to be routed to a wired VoIP endpoint (e.g. PC)

Yours faithfully,

Adrian Kennard

Julia Snape, Office of Communications

Dear Rev Kennard

Thank you for your request for information about in how many cases Ofcom has granted telecoms providers exceptions to the National Numbering Plan rules relating to 07 mobile numbers which we received on 28 August and have considered under the Freedom of Information Act 2000.

In response to your request, we can neither confirm nor deny that we hold information relating to this request. The information is not readily accessible as a considerable amount of time would be needed to locate, retrieve, identify and extract any relevant information. With no time parameters, it would mean identifying records from a wide range of years and then doing a manual search of each of those. Section 12 of the Freedom of Information Act 2000 provides that a public authority is not obliged to comply with a request for information if the authority estimates that the cost of complying with the request would exceed the “appropriate limit”. The appropriate limit is set out in the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004, and is, for Ofcom, £450. That sum is intended to cover the estimated costs involved in determining whether Ofcom holds the information requested, identifying, locating, retrieving and extracting the information from any document containing it. The Regulations provide that costs are to be estimated at a rate of £25 per person per hour.

Ofcom estimates that it would take more than 18 hours to identify, locate and extract the information you require and as such the cost of complying with your request will exceed the appropriate limit. We will therefore not be able to provide any information in connection to your request.

More information on this section of the Act can be found here: http://www.legislation.gov.uk/ukpga/2000....

However, if you wish to submit an alternative request with a narrower, more specific scope in relation to this subject, we would be happy to give it our full consideration. In any event, with any information requested, exemptions may apply.

Please quote the reference number above in any future correspondence as this will help us to deal with your query more quickly.

Kind regards
Julia

If you are unhappy with the response or level of service you have received in relation to your request from Ofcom, you may ask for an internal review. If you ask us for an internal review of our decision, it will be treated as a formal complaint and will be subject to an independent review within Ofcom. We will acknowledge the complaint and inform you of the date by which you might expect to be told the outcome.
The following outcomes are possible:
• the original decision is upheld; or
• the original decision is reversed or modified.

Timing
If you wish to exercise your right to an internal review you should contact us within two months of the date of this letter. There is no statutory deadline for undertaking internal reviews and it will depend upon the complexity of the case. However, we aim to conclude all such reviews within 20 working days, and up to 40 working days in exceptional cases. We will keep you informed of the progress of any such review. If you wish to request an internal review, you should contact:

Graham Howell
The Secretary to the Corporation
Ofcom
Riverside House
2a Southwark Bridge Road
London SE1 9HA

If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

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Rev Adrian Kennard

Dear Julia Snape,

OFCOM must surely keep a record of any exceptions granted to the numbering plan as otherwise you would not be able to enforce the numbering plan. I cannot believe it would take 18 hours to check such records.

However, I would like to revise my request and constrain it to the major mobile operators only (O2/Three/EE) and previously T-Mobile/Orange/Cellnet. This should mean checking only 6 files to see what exceptions have been granted and should therefor fit within your timescales.

Yours sincerely,

Rev Adrian Kennard

Nige Coleman left an annotation ()

Ofcom, despite being one of the most affluent regulators (CE £320k PA, average employee salary £70k) is also profoundly lazy and incompetent. They operate in a self-serving manner, only taking action when they believe it will enhance their public image and ignoring their statutory duty when it does not, often resulting in a breach of human rights.

Ofcom regularly break the law (frequent breaches of the DPA, failure to take enforcement action on behalf of authorised users of the radio spectrum; they gave me the name and address of the primary perpetrator in my Ofcom case in a shocking breach of the DPA).On whatdotheyknow you will see frequent misses in the required time-scale and schoolboy errors.

Take https://www.whatdotheyknow.com/request/o... for example. Ofcom ignore the request beyond the deadline. The submitter requires an internal review because they have broken the law. Ofcom then reply with a standard response, ignoring the requirement for an internal review. Ofcom next make an outlandish response: they apologise for sending the previous response in error then state they had no record of the FOIA. How then could they have responded in the previous message if they had no record of his request! Ofcom at no point conducted an internal review as required. Ofcom is not fit for purpose and should be dissolved without delay.

It may interest you to know that the submitter of the FOIA linked above has contacted me privately with the court case number and demonstrated that Ofcom have LIED in their eventual response to the FOIA! . . Their performance is shameful.

Julia Snape, Office of Communications

Dear Rev Kennard

Thank you for your revised request for information about exceptions granted to the numbering plan to mobile operators O2, Three, EE, T-Mobile, Orange and Cellnet. We have considered your revised request under the Freedom of Information Act 2000.

Again, we can neither confirm nor deny that we hold information relating to this request. The information is not readily accessible as a considerable amount of time would be needed to locate, retrieve, identify and extract any relevant information. With no time parameters, it would mean identifying records from several hundred dating back to 1994. All of the providers have a vast amount of numbering allocated over a wide range of years - the information is not contained within 6 files as each allocation of numbering is treated as an individual case. Section 12 of the Freedom of Information Act 2000 provides that a public authority is not obliged to comply with a request for information if the authority estimates that the cost of complying with the request would exceed the “appropriate limit”. The appropriate limit is set out in the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004, and is, for Ofcom, £450. That sum is intended to cover the estimated costs involved in determining whether Ofcom holds the information requested, identifying, locating, retrieving and extracting the information from any document containing it. The Regulations provide that costs are to be estimated at a rate of £25 per person per hour.

Ofcom estimates that it would take more than 18 hours to identify, locate and extract the information you require and as such the cost of complying with your request will exceed the appropriate limit. We will therefore not be able to provide any information in connection to your request.

More information on this section of the Act can be found here: http://www.legislation.gov.uk/ukpga/2000....

However, if you wish to submit an alternative request with a narrower, more specific scope in relation to this subject, we would be happy to give it our full consideration. In any event, with any information requested, exemptions may apply.

Please quote the reference number above in any future correspondence as this will help us to deal with your query more quickly.

Kind regards
Julia

If you are unhappy with the response or level of service you have received in relation to your request from Ofcom, you may ask for an internal review. If you ask us for an internal review of our decision, it will be treated as a formal complaint and will be subject to an independent review within Ofcom. We will acknowledge the complaint and inform you of the date by which you might expect to be told the outcome.
The following outcomes are possible:
• the original decision is upheld; or
• the original decision is reversed or modified.

Timing
If you wish to exercise your right to an internal review you should contact us within two months of the date of this letter. There is no statutory deadline for undertaking internal reviews and it will depend upon the complexity of the case. However, we aim to conclude all such reviews within 20 working days, and up to 40 working days in exceptional cases. We will keep you informed of the progress of any such review. If you wish to request an internal review, you should contact:

Graham Howell
The Secretary to the Corporation
Ofcom
Riverside House
2a Southwark Bridge Road
London SE1 9HA

If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

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Dear Julia Snape,

I am shocked that OFCOM is that disorganised, but I will revise my request again to fit within time scales. As all of the mobile operators provide 07 mobile numbered services in ways that are not allowed by the numbering plan as it requires all signals to use a wireless link to a mobile handset (voicemail, divert to non mobile, and in some cases VoIP) - it is clear OFCOM have granted exceptions to the plan.

So, for each of the following specific numbering block allocations in use (one by each major operator), please advise when an exception was granted and the nature of that exception.

I trust that this will fit the time constraint.

079737 Orange
079560 EE
079550 Telefonica
079170 Vodafone
075750 Hutchison

Yours sincerely,

Rev Adrian Kennard

Julia Snape, Office of Communications

1 Attachment

Dear Rev Kennard

Please find attached our response to your request for information.

Kind regards

Julia

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Dear Julia Snape,

I am sorry but you are being deliberately evasive now.

My original question was general and as such you could disclose, and you choose not to as would take to long. I narrowed the question to specific examples which you cannot disclose as they are specifioc examples.

Please answer my original question but do so using any arbitrary 07 mobile number examples you wish to pick in order to reduce the time scales to be within acceptable levels and feel free not to disclose commercial sensititive information such as specific number blocks or company names.

Yours sincerely,

Rev Adrian Kennard

Vincent Aleck left an annotation ()

perhaps you should submit a separate request to ask them for information on how they store or record the type of data you're after, and what sorts of queries are possible. Then you could request the specific data you want. And remember that it's probably not answered by an IT person so keep it non-technical.

Julia Snape, Office of Communications

1 Attachment

Dear Rev Kennard

Please find attached our response to your request for information.

Kind regards

Julia

show quoted sections

Rev Adrian Kennard

Dear Julia Snape,

Thank you for your reply. It is interesting to know that no exceptions have been granted, as mobile operators clearly breach them for 07 mobile numbering all of the time. Sending a call to voicemail does not involve wireless telegraphy to a mobile handset, neither does diverting to a landline or connecting via Internet to a wired laptop or PC.

I'll make a separate FOI request regarding the process OFCOM has for getting in to this little club of mobile operators that seem exempt from enforcement of these rules. As I run a company with an 07 mobile block, I would love to have the same freedom as those operators.

Yours sincerely,

Rev Adrian Kennard