Ever wonder what happens behind the scenes when law enforcement gets involved in tracking down a harassing phone call? It’s not all detective shows and dramatic revelations. Often, it’s about meticulous work by organizations like the Industry Traceback Group (ITG), who piece together the puzzle of phone networks to find the culprit.
For phone service providers, this means occasionally getting a polite (but urgent) inquiry from the ITG about a suspicious call. One of our clients received just such an inquiry recently, and has kindly agreed to share what happened, so you can be better prepared when this happens to you.
Note that the ITG’s primary purpose is to track down suspected illegal robocallers, but they can also be involved in other law enforcement activities tracking down the source of phone-based harassment (which is what happened in this example).
An email from the Industry Traceback Group
This situation all started with the following email from the Industry Traceback Group.
Our client reviewed the CDRs from their system, and confirmed that this call really did happen, then clicked on the provided link to see what they were supposed to do. When you first visit the ITG portal, you’re required to create an account, and then fill out a form with more information about the call and the client who made the call.
Who made the harassing call?
Before filling out the form, our client decided to contact the customer, to discuss the situation. He writes:
- I explained that we had received notice of inappropriate calling via a carrier-to-carrier group dedicated to stopping illegal robocalling and other unwanted calling. I explained that other than the date/time and from/to phone numbers, all I knew about the situation was that abusive/harassing phone calls were made. I explained that this calling behavior was a violation of our acceptable use policy and needed to stop.
- The client explained the nature of their business, and the phone in question is a courtesy/lobby phone made available to their patrons (essentially, the public).
- The client already had some degree of supervision over the phone’s usage in place, but made a commitment to improve this. We also discussed the possibility of adding mandatory account codes and/or call barring to the line to give the client greater control over who uses it.
Obviously this conversation could have gone very differently, depending on the particular circumstance. Perhaps the caller might have been a business making high-volume outbound calls, or perhaps the actual person who had done the harassing. It’s important that you have a clearly documented Acceptable Use Policy for your subscribers, and also that you have a documented procedure for what you will do if you discover that one of your subscribers is placing illegal robocalls – this is part of the Robocall Mitigation Plan that you should have filed with the FCC.
How to complete the paperwork:
Once he understood the situation, our client was able to fill out the form on the ITG’s online portal.
On subsequent forms our client was asked whether the call in question was signed with STIR/SHAKEN (it was), and even to provide the encrypted SHAKEN header (which our client was able to find in ClearIP – their STIR/SHAKEN provider).
After completing those forms, you can submit the response, and that’s that.
Post-Script: The big carriers move more slowly than the ITG
About a week later, our client received an email from their upstream provider, asking them to explain the same problematic call. It seems like this upstream provider had responded to the ITG, but then through some slower, internal process, had finally gotten around to doing their own investigation.
Our client was able to provide a summary of the situation to the upstream provider, and share that they’ve already communicated with the ITG – at which point they seemed satisfied.
Make sure you have a plan
This particular situation went very smoothly, but it’s worth making sure you’re prepared in case you’re ever contacted.
- It’s important that you have good Know Your Customer policies, and Acceptable Use Policies in place (although I’d imagine that “doing illegal stuff” is automatically unacceptable, even if you didn’t write it in your policy).
- The Robocall Mitigation Plan you filed with the FCC should describe the actions you’ll take if you identify one of your subscribers as the source of illegal robocalls, so you should make sure that information is shared with the right people.
- It’s a legal requirement to cooperate with the ITG in a timely manner (note the 24-hour turnaround – basically 1 business day) that is mentioned in the letter above.
Being contacted by the Industry Traceback Group might initially seem daunting, but it’s a crucial part of maintaining the integrity of our phone networks. By cooperating with the ITG, phone service providers play a vital role in stopping robocalls, as well as other abusive calls, ensuring a safer and more pleasant experience for all users. So, next time you get that inquiry, remember: you’re a key player in a larger effort to keep the lines clear and the conversations kind.
