The Indian mobile handset market, second largest in the world, has been plagued by the problem of Unsolicited Commercial Communication (UCC). Despite regulation in the form of a Do Not Disturb (DND) registry being present since 2010, there has been little respite from calls from telemarketers. These UCC or popularly called spam, continue to dodge rules and bypass all systems. What is even more worrying is the menace of fraudulent calls and messages, as an issue that has been red-flagged by regulators, like SEBI (Securities and Exchange Board of India) and RBI (Reserve Bank of India). In this backdrop the Telecom Regulatory Authority of India (TRAI) decided to completely overhaul the regulation to effectively deal with the nuisance of spam. The adoption of distributed ledger technology (or blockchain) as the RegTech to ensure regulatory compliance is the centerpiece of the new regulation.In a chat with ET Digital, Uday Reddy, CMD at Tanla Solutions talked about the significance of safeguarding consumers against UCC, privacy breaches and the role of technology. Edited excerpts.ET Digital (ET): Recently there has been a lot of buzz around implementation of TRAI’s recent regulation on safeguarding customers against unsolicited messaging and communication. As a player in the customer communication space what is your stance on this?Uday Reddy (UR): At Tanla, we are extremely customer centric and our focus remains on enhancing customer experience with efforts directed at minimising spam, fraud, and privacy breaches. In this context, the recent notification of the ‘Telecom Commercial Communications Customer Preference Regulation’ (TCCCPR) by TRAI is a welcome step. It is a commendable step in the right direction to drive compliance and create a cleaner ecosystem for all the participants. The regulation is particularly pathbreaking as it envisages using customer-preferences and technology at its heart to complement and enable the regulatory objectives.ET. Why was there a need to come up with a regulation to curb unsolicited communication and what impact does it have on brands and their marketing ROI’s.UR: How brands communicate and interact with their customers, one-on-one, even at a small service level, goes a long way in building the image and an overall perception of the brand. Not knowing or not ensuring what is welcome by the customer and what is not, can often lead to end-users being bombarded with communication which is either not wanted, not relevant, too frequent or timed inappropriately. Hence, the term ‘unsolicited’. Unsolicited messages are one major cause of disturbance and often looked at as intrusive by the recipients.It is a much larger issue than just unsolicited communication for any brand, where they are spending millions to acquire customers and build attributes, even a minor privacy breach however unintentional, can lead to the loss of the customer as well as tarnish the brand image resulting in a multiplier effect in today’s digitally connected consumer world.Without having a control on customer communication across channels it is difficult for marketers to influence the perception of consumers and their attitude towards the brand, while also wanting to stimulate their actual purchasing behaviour. If dealt with appropriately, all of this consequently increases sales, maximizes market share, and develops brand equity.ET: What is the role of Companies like yours in the implementation of the said regulation?UR: As pioneers in the cloud communication space in the country, we have always been poised to efficaciously build consensus among not just the key players in the ecosystem, but also earnestly uphold the regulatory requirements for the development of a wider use case. Within few months of the announcement of TRAI’s new regulation in July 2018, Tanla was able to build and launch the first of its kind blockchain enabled commercial communication stack, Trubloq, for the telecom sector, the unveiling of which was done during the Mobile World Congress 2019, in Barcelona, Spain. The solution was developed keeping in view absolute compliance with the regulation (TCCCPR 2018) and empowers individual mobile users to set and manage their communication preferences and consent. 77276732ET: What technology enhancements and changes were required to build such a solution?UR: Despite making significant changes in the regulations and frequent updates, most of the regulations globally have met with limited success in curbing unwanted commercial communications and its impact on customers. Owing to this, the new regulation sets out to integrate blockchain or distributed ledger technology (DLT) in the control framework of its existing regulatory mandates. Building such platforms require multidimensional architecture, which focuses not only on transactions, but also on building accountability. We also leveraged on machine learning and artificial intelligence to further identify patterns to flag fraudulent behaviour, eliminate unregistered entities and ensure data privacy. This unique blend of regulation with innovation and technology was essential to build a highly disciplined and trusted commercial communication ecosystem.ET: What were the critical considerations for Trubloq that ascertain at its core not just compliance to the regulation but also effective functionality?UR: To start with, the identification and use of the right technology was of prime importance to enable both compliance and the functionality of such a platform. Through distributed ledger technology, which is the technology underlying Trubloq, TRAI will be able to significantly enhance customer preferences and consent registration with a considerable reduction in the overall turnaround time. With all information now being maintained on distributed ledgers, the process of registration and implementation of choices is going to be more efficient, faster, and accurate.It also strengthens traceability by maintaining digital records and eliminating voice or written consents.The regulation also mandates registration of senders, their header (sender names), message and voice content templates bringing immense transparency in every transaction, which would drastically improve the customer complaint management and redressal system. Whitelisting all critical elements further strengthens the scrubbing capabilities while securing customer information.ET: Is this a welcome step for enterprises? How has their response been to the implementation of the regulation? UR: SMS based direct consumer communication is one of the most effective channels of customer engagement for most of the enterprises, across industries. They use it not only for promotional communication, but also leverage the same for sending out informational content like regular updates on loyalty points balance, critical OTPs for account validation etc. Therefore, a secure and reliable messaging platform is at the very foundation of any customer-led enterprise. In this regard, TRAI’s regulation is undoubtedly a welcome step to curb spam messaging and potential fraud. Enterprises are keen to implement this new initiative and are optimistic about the positive impact this will bring to end-customers and their businesses alike.ET: Customer consent, privacy and spam are global issues. Where do you see the implementation in the larger picture?UR: Globally, regulators have tried varied means and in varying degrees of success to ensure that customers are safeguarded from unsolicited commercial communication (UCC) and subsequent frauds and privacy breaches. This includes introducing various regulations, defining penalties, driving customer awareness programs etc. However, in the absence of technology to monitor such initiatives, it has been increasingly difficult to ensure a high degree of compliance and customers still are subject to spam and phishing.We are confident that DLT based platforms like Trubloq can be implemented globally adhering to different telecom customer communication regulations across the globe. In fact, we already have conversations under-way with mobile operators in other geographies for signoffs on DLT deployment.ET: We already have systems like DND in place. What are the limitations of such a system, and what has it been able to achieve?UR: The widespread use of commercial communication is accentuated by the fact that over 30 billion messages are sent in India alone in a month. A lot of these messages are not aligned with customer consents and preferences and are hence classified as UCC. Despite the prevalence of a “Do Not Disturb directory” or DND as it is referred to, unscrupulous elements have found ways to bypass the directory and target customers through UCC. These regulations added a lot of value towards safeguarding customers choice and preferences, however, customer consents and preferences were not updated in the NDNC, and NCPR registers on a real time basis, further allowing telemarketers to continue sending commercial communications to customers. Additionally, consents were registered in an unverifiable and unauthenticated manner without any traceable proof. Scrubbing techniques were also not the most efficient and, in most cases, failed to restrict sending messages to customers enlisted in the NDNC and NCRP registersET: What do the Mobile Network Operators make of this regulation? What is their reaction? UR: Mobile Network Operators (MNOs) have conservatively estimated that close to 10% of A2P revenues are lost to frauds, which are approximately $ 1.5 billion in a year of over $ 16 billion A2P market. Perpetrators have identified numerous ways of dodging the existing controls landscape and have been successfully bypassing systems, networks, firewalls, etc. The implementation is going to significantly and ambitiously bring down the negative implications of such fraudulent perpetrators at work. It will pave the way for a stronger system that stands firm on trust and security.