Ozg Lawyers @ Ozg Lawyers @ Ozg Lawyers @ Ozg
Lawyers
Some new born Startups proposed
that the contact center be run over a cloud-hosted telephony system. As per
their model, calls would be generated from abroad, sent to a Cloud Hosted Automatic
Call Distribution System (ACD) which would also be based abroad, and then
routed over to the India-based contact center. Agents sitting in the contact
center would connect to the ACD accounts to receive and make calls. The
argument fundamentally was that, since there is no PSTN anywhere in the whole
setup, and the whole contact center has no possibility of PSTN-VOIP merging,
the contact center would legally comply with OSP norms.
DoT guidelines explicitly
state that Voice traffic must be routed through MPLS, Point to Point link or
PSTN path only. In India, carrying voice over the Internet for commercial use
is not allowed. There are any number of reasons for this, but the salients ones
are:
·
The Voice managing server is
outside India, so DoT and security agencies become worried about getting access
to the ACDs and the CDRs and system logs.
·
Additionally, from a security
point of view, in this model, it becomes far more difficult to capture and
decrypt voice conversations.
Note that one of the key
defining requirements for OSP approval is that national security requirements
be maintained — and this variant of the cloud-hosted model clearly fails that
requirement. DoT does not approve these kinds of architectures. All OSPs will
need to take the connection from India based authorized VoIP service providers
only.
Finally, when we see
the Clarification Terms and Condition for OSP dated №18–1/2009-CS-1
Dated: the 25th February, 2009, issued by the DoT, it explicitly mentions
that “use of Foreign VoIP minutes by OSPs is not permissible”.
In short, our advice to all
OSPs that intend to use cloud-hosted systems in this fashion is simple — avoid,
avoid, avoid! Remember the cost of compliance may seem high, but it is far
lower than the cost of being caught in non-compliance.
OSP Compliance Consultant
DoT OSP Compliance Consultant in Mumbai / Bangalore /
Hyderabad
Ozg Lawyers @ Ozg Lawyers @ Ozg Lawyers @ Ozg Lawyers
Ozg Lawyers @ Ozg Lawyers @ Ozg Lawyers @ Ozg Lawyers
Email: ask@osplicense.com
