4G and 5G "default address": data protection

Overview: legal obligations to provide EAs (Emergency Services agents; Ambulance, Police, Fire and so on) with "location information". Due to a legacy of historical telephone legislation, originally intended for fixed lines, there are ongoing changes to UK legislation that affect "4G" and "5G" data SIMs. This article is intended to provide links to resources about the current progress being made, and the advised actions that CPs (Communication Providers) can take to demonstrate a responsible and cooperative working practice.

Communications Act 2003http://www.legislation.gov.uk/ukpga/2003/21/contents

This act requires CPs to keep a record of the "location" (for fixed lines, this would usually be the address) of the caller. Due to the mobile nature of "4G", "5G" and VoIP, this 2003 act underwent consultation and amendments were put forward 8-Mar-2019: https://www.ofcom.org.uk/about-ofcom/latest/bulletins/competition-bulletins/all-closed-cases/cw_996

Whilst the interpretation of these laws awaits full implementation of the recommendations, the 2003 law requires the following:

“to the extent technically feasible, make accurate and reliable Caller Location Information available for all calls to the emergency call numbers “112” and “999” (General Condition 4.2)

Usually, cell tower trigonometry is provided by the main UK networks. However, to demonstrate a measure of responsibility, we record a "default address" that is lodged on file as "the main intended address" where the service will be used. If cell tower data is unclear, or the device is offline, this default address is provided to EAs. In the rare event of a legal subpoena, or police request, this same address is provided. As a company we are registered with the UK ICO so as to protect such address data inline with GDPR and UK regulations - see https://ico.org.uk/ESDWebPages/Entry/Z1040541 Since such address data is only shared with EAs under very specific, and very rare, circumstances, we can assure customers and partners alike that such data will never be used for marketing purposes. All partners and suppliers in our supply chain are bound by the same strict regulations for protecting this data.

The main UK mobile operators are actively demonstrating their responsibility to work together for public good, and have formed a group called "The Mobile Broadband Group (MBG)", whose members include the UK businesses of EE, Telefonica UK, Three and Vodafone.

See https://www.ofcom.org.uk/__data/assets/pdf_file/0027/74295/mobile_broadband_group.pdf

Whilst we await full implementation of refinements to the legislation, we appreciate the cooperation of end users and partners when we ask for a "default address" when we provide a new SIM service.