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April 2003
ENUM is a technology "protocol" that allows the translation of normal telephone numbers into a format that can be used to store and retrieve Internet addressing information, which can in turn be used to route communications over the Internet. As such, ENUM can help bridge the gap between the traditional telephone network and the Internet. With ENUM and "Voice over Internet Protocol" ("VoIP") technology, an increasing amount of voice communications can be carried over the Internet instead of over the telephone network. Initially, ENUM is likely to be deployed by corporations and other large institutions that seek to reduce their use of traditional telephone services. This technology has the potential to allow large and small users to save money and increase control over and flexibility in their communications.
But ENUM's potential benefits also bring risks in terms of privacy and other public policy concerns. The simplest implementation of ENUM envisions that individuals' personal contact information (such as telephone numbers and e-mail addresses) will be stored in special records located in the Domain Name System (or DNS) of the global Internet. Because the DNS is publicly available, the use of ENUM could significantly compromise the privacy of its users.
A more complex use of ENUM (in conjunction with a "proxy server"), however, offers the opportunity to gain the benefits of ENUM without sacrificing control over personal information. To promote the availability of this approach, any implementation of ENUM should follow a number of important guidelines to ensure that there is a diversity of ENUM service providers and that those providers are able to offer privacy-protecting ENUM options. This paper lists 14 specific policy recommendations, found in Section II.C below.
One critical aspect of the global public policy issues surrounding ENUM is the fact that ENUM will, to a large extent, be implemented within each country by the telephone authorities or companies that operate within that country. Thus, many critical decisions (for example, about how much information will be required to obtain an ENUM number) may be made on a country-by-country basis. Because there are important potential privacy and policy risks raised by ENUM, it is vital that within each country, the relevant authorities must closely consult with the public interest and civil society sector, the communications industry, and the computer industry.
ENUM does offer important potential benefits, and if implemented correctly it can enhance rather than harm individual privacy. But any country seeking to implement ENUM should pay close attention to the important issues of public concern that it raises.
For more information, contact John Morris at jmorris@cdt.org or +1-202-637-9800
The report is currently available as an Acrobat Reader File. An html version will be available shortly.
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