Ofcom’s policy to date in enforcing the proper use of personal numbers (and indeed other numbering types) has been to focus almost exclusively on the obligations of the CP to whom a particular number range or block has been allocated (the “range holder”). The main benefit of this approach is that it enables Ofcom to identify speedily from the National Numbering Scheme the relevant CP that has been allocated the telephone number in question (as opposed to a sub-allocation from that CP to another). This enables Ofcom to access contact details of the relevant range holder without delay, to ensure that the range holder terminating the relevant number(s) can respond swiftly to any apparent misuse.
However, it has become clear to Ofcom more recently that there may be a number of CPs seeking to avoid the restrictions on the use of 070 numbers by offering services via numbers obtained from a series of different range holders. Ofcom has become aware of some examples of ‘shopping around’ by those apparently seeking to circumvent the restrictions on the use of 070 numbers, with some CPs simply switching between range holders when the misuse has been detected. Such behaviour by an apparently small number of CPs undermines the integrity of the number range and is detrimental to both range holders and consumers. Ofcom therefore proposes to amend the Guidelines as set out in Section 2.