Opinion of Japan ISP association on Article 5A.8

[Takashi Kimura / Japan <kimura.takashi@xxx>]

October 29, 2012

Opinion of Japan ISP association on Article 5A.8

Japan Internet Providers Association (JAIPA) is a sole representative
of Internet service provider companies in Japan with about 180 members,
which covers about 90% of Japanese broadband Internet users. We are
aiming to promote the healthy development of Internet businesses and to
contribute to the development of sophisticated ICT society,

Having reviewed the Draft of the future ITRs, we would like to
contribute to the following for your consideration in the discussion
during the WCIT-12.

Our contribution to the ITRs relates particularly to Article 5A.8 which
states:

“5A.8 Member States shall ensure that operating agencies duly identify
the subscriber when providing international telecommunication services,
and shall ensure the appropriate processing, transmission and protection
of identification information in international telecommunication networks.”

We are concerned that obligating subscriber identification to operating
agencies leads to obligation of operators to confirm subscribers’
identity at service registration or during sign up process and will
become a barrier to development of new telecommunication services. There
are various telecommunication services which do not require confirmation
of subscriber information in using them and we think that not all
telecommunication services need user identification. Therefore, we
oppose to the proposed modification of 5A.8.

Taketsune Watanabe
Chairman