SIM Card Registration is defined as the process of recording and verifying the personal details of a subscriber by a GSM service provider. The said details normally include the phone number(s), name, date of birth, gender, address (postal or physical address), alternative telephone contacts if available and the identification document and number of the identification document presented.
SIM Card Registration is traditionally voluntary until a deadline is set by the Authority from which point it becomes mandatory. The SIM Card of any subscriber who fails to register by the set deadline is disconnected and deactivated by the GSM operator and the subscriber loses their number.
This exercise is aimed primarily to the reduction of mobile phone related crime such as money laundering, cyber terrorism, prank calls and other such crimes. In addition, this exercise enables government to monitor and verify the actual tele-density figures and active lines in the industry thus ensuring that the tax revenue from mobile services correlate with the data presented by the GSM operators.
SIM Card Registration is currently under way in Ghana, Sierra Leone Nigeria, Zimbabwe, South Africa, Kenya, Singapore, Malaysia, Geneva, India, Egypt and various other countries.
LEGAL MANDATE IN THE GAMBIA
In order to ensure that a project of such nature is successful and not challenged by the parties affected it is fundamental that a legal framework be established to support it. A legal framework further contributes to the transparency of the entire process.
“Information and Communications service providers shall maintain subscriber lists for keeping data that is necessary for the identification of subscribers and for the services used and that can be processed by the service provider under authorization.”
Further, section 32(o) of the Information and Communication Act provides that the Licence of the service provides shall contain “conditions relating to the registration of Subscriber Identity Cards by service providers.”
Thus the requisite legal mandate with regards to SIM card registration has been established and included into the regulatory framework including the licensing framework.
PURA in consultation with stakeholders had determined that January 15th 2012 would be the mandatory date for the registration of old SIM cards. In order to ensure an effective and successful implementation phase, an extensive sensitisation plan was effected.
ACTIVITIES CARRIED OUT UNDER THE SIM CARD REGISTRATION PROJECT
PURA in conjunction with the GSM operators embarked on an extensive nationwide sensitisation campaign in order to allay the various misconceived concerns and apprehension with regards to SIM Card Registration. PURA in consultation with all stakeholders (GSM Operators, MOI, and MOICI) embarked on a country wide sensitization with regards to SIM Card Registration the purpose of which is to educate members of the general public on the advantages of the exercise and the rationale behind the exercise. By engaging the general public continuously and transparently the level of apprehension and fear was swiftly combated thereby leading to the successful implementation of the project.
As this is a consultative process, the GSM operators have provided to PURA various assistances with regards to the sensitization such as:
Free radio airtime
Free TV airtime
Bill board space
Newspaper space etc
The specific sensitisation campaigns were as follows:
PURA with the support of the Ministry of Information & Communications infrastructure commenced a weekly TV programme on Tuesdays at 9 pm from December 5th 2011 for a period of 8 weeks. The objective of the programming was to engage an extensive range of the members of the general public with regards to the SIM card registration exercise. The programmes ranged from live TV programmes which catered for telephone call ins, recorded TV programmes which also catered for interviews, or viewing of particular events such as workshops. The TV programmes created conducive environment for members of the general public to have a greater understanding and appreciation of the SIM card registration project.
PURA used the radio stations as a medium to reach the masses many of whom may not necessarily have access to Televisions sets. Radio programmes took various forms such as interviews, panel discussions and also one minute jingles. The jingles were played up to four times a day in all the local languages on a minimum of 10 commercial radio stations and all the community radio stations.
PURA utilised billboards in strategic locations which bore images of SIM cards of various operators and also of the various ID card types that were approved for use to register. Furthermore, PURA utilised the newspapers for press releases and various information.
PURA also contracted Nfansung Jamano, a performing arts group, for 24 drama skits in all local languages on various aspects of SIM card registration. The objective was to ensure that the members the general public would understand the issues with regards.
SUPPORT FOR SENSITISATION.
The following support was provided by the GSM operators as part of the joint sensitisation:
GRTS TV talk show, twice a month, Monday and Wednesday from 9.45-10pm
Radio talk show, once a week, for a period of 6 months
2 bill6x3 located at Elton filling station Kotu
1 hour talk show on Paradise FM every Saturday from 2-3pm
12 spots of radio per day on paradise FM
Free newspaper slots
Free Radio airtime on a daily basis
Free jingle airing
A national workshop was held on 12th January 2012 at the Paradise Suites hotel. The objective of the workshop was to engage and educate all stakeholders with regards to the exercise which became effective shortly thereafter. Participants of the workshop included but were not limited to Government Ministries, members of both the print and broadcast media, members of the civil society and consumer groups, students and representatives of the ICT sector.
The workshop agenda focused on the following topics:
Regulation, market structure and Growth of the Telecom sectors (PURA)
SIM Registration Why/How/Challenges
Complaints Resolution and the Role of the Police and Judicial establishment.
SIM Registration in Ghana: Lesson Learnt Regional Regulator/Expert
Voluntary SIM Registration: GSM Operators Experience so far
Approach (Sensitization campaign)
NATIONAL ASSEMBLY PRESENTATION
PURA on the 6th day of January 2012 also visited and presented the SIM Card registration exercise to the National Assembly. PURA was of the belief that the National Assembly as the law makers and representatives of various constituents in the Gambia should be updated with regards to the progress of this national issue.
The presentation to the Assembly members focused on the rationale behind the exercise and the process and procedures which would be followed. It was an interactive session which allowed for the Assembly members to share ideas on ensuring the better implementation of this exercise.
MEDIA TRAINING WORKSHOP
PURA held a media sensitisation workshop on Saturday 28th January 2012 for journalists and media practitioners for all radio stations and newspapers in The Gambia.
Media practitioners were identified as essential towards ensuring the successful implementation of this project in view of the fact that the population listens to the radio, views the television and reads the newspapers. Thus the journalists were viewed as the voice of the project.
However, PURA realised that the workshop was essential in order to ensure that the general public are efficiently informed of the exercise. The reason being that once people know the importance and significance of the SIM Card registration then they will participate and take ownership of the project. By the end of the workshop, the media practitioners were enlightened with regards to this project and each and every participant pledged free airtime or news item space from their respective companies.
The sensitisation campaign took various forms as the ultimate objective was to ensure that the correct information was disseminated to the various segments of the population who were also provided with an avenue to raise any concerns of queries.
GSM OPERATOR CUSTOMER CARE STAFF TRAINING
During the course of the consultation with the GSM operators, PURA realised that although task force representatives were senior members of the service providers, the actual persons who would be implementing this project would be the customer care supervisors. Thus it was determined that extensive long term training sessions were required for all customer care staff of the service providers in order to ensure that they would be able to address the concerns or questions of their subscribers.
PURA trained the customer care staff for all the GSM operators over a period of 3 months from January to March 2012 at the PURA head quarters. The training sessions scheduled for 4 hours per session were done in groups in order to cater for the large number of customer care staff which ranged a total of at least 500. Over the training period, customer care staffs were trained in the following areas:
SIM Card registration- why and how?
Role play- how to address real life issues and questions
Test and on the spot quizzes
CONSULTATION WITH STAKEHOLDERS
In reviewing the SIM Card registration exercises in the sub region, it was realised that one of the main reasons for the many failed attempts was the failure on the part of the regulator to consult and partner with the relevant stakeholders.
Although SIM Card registration is an exercise that involves the registration of personal details of subscribers, the objective of the exercise itself is to enable the relevant security forces to positively identify and trace individual as and when required. Thus, due to the rapid increase in usage of mobile phones and the high penetration and coverage rates, SIM Card registration is the most effective mean to identify a high percentage of the population to be identified.
It should be noted however that the means by which the subscribers are identified are with identification documents for which neither the GSM operators nor PURA are the custodians of. In order to avoid creating a similar scenario as was done in other jurisdictions where identification details where collected by the GSM operators and the regulator and could not be verified which would therefore defeat the objective of the exercise, PURA formed partnerships with both IEC and GID.
Although, Immigration was initially identified solely for the Bio metric ID card and drivers license, IEC was also identified in the latter stage when it was realised that a very high number of Gambians are in possession of voter’s card as a result of the recently concluded Presidential elections. Thus IEC was co-opted into the task force for verification.
The role of these two institutions is crucial to the success of the project as the data that is collected by the GSM operators must be forwarded to them by PURA in order to verify the validity of the data. Thus the personal details collected by the GSM operators can only be determined to be valid once verified by the Immigration department and IEC.
It must be noted that a SIM Card is only considered as registered once the data collected by the GSM operator is verified by the relevant body as valid. This is necessary in order to ensure that an individual can be identified as and when necessary with the data collected by the GSM operator.
MOU AGREEMENTS WITH THE GAMBIA IMMIGRATION DEPARTMENT (GID)
AND THE INDEPENDENT ELECTORALOFFICE (IEC)
MOU’s have been signed with both the IEC and GID detailing the aims of the partnership agreement.
As part of the agreement, IEC has agreed to provide 8 members of staff to the verification task force whose job function over the duration of the project shall be to verify the personal data specific to voter’s cards. IEC is also providing the computers and database for the verification. The verification shall be done at the IEC head quarters.
As per the agreement, GID has agreed to provide for PURA’s assistance 10 members of staff to the verification task force whose job function over the duration of the project shall be to verify the personal data specific to the Bio metric ID cards, Driver’s licence and passports.
SIM CARD REGISTRATION REGULATIONS
The regulations provides for the de activation of the unregistered lines on the identified date of June 15th 2012 as well as penalties for non compliance with the regulatory framework for the exercise.
The MOJ have submitted the regulations to MOICI for signature by the Honourable Minister. The effective date for the regulations is June 1st 2012
June 15th 2012 was identified as the deactivation date for any person who has not registered their SIM card. This deadline was eventually extended to 15th of January 2013 to enable the operators register more consumers.
MONITORING AND EVALUATING
As part of the ongoing monitoring and evaluation, PURA established monitoring teams who were assigned to different GSM operators. The roles of the monitoring teams were to visit the various registration sites and provide on the ground training. It was realised that although the customer care staff were trained by PURA, issues on the ground sometimes deviated from the structures that were provided. In addition, PURA monitoring team where tasked to review the data bases where the subscriber information was being inputted to ensure that minor errors were detected.
In addition, PURA inspected the collection and storage processes of each GSM operator in order to determine the compliance with the data protection law.
The provincial registration of SIM Cards was delayed due to the various challenges that PURA faced once the project became effective. The customer care trainings needed to be intensified as many errors were identified with the registration processes by the monitoring teams.
PURA determined that it would not be effective to embark on the provincial tour until many of the issues were addressed. Thus 16th April 2012 was identified as the kick off date for the provincial tour.
This segment of the project was done in consultation with the Ministry of Local Governments and Land and the operators. For logistical and monitoring purposes it was determined that a joint convoy would be undertaken as opposed to individual registration by GSM operators. All the operators provided teams that participated in this exercise to every corner of the country for eight (8) weeks.