7. There is no reference to redress an issue to give a chance to aggregator/telemarketer to explain the reason for sending a particular SMS against which there has been complaint. A competitor could complain and easily shut down a telemarketer’s business. The aggregator/telemarketer needs to be given a fair hearing and seek redressal.
8. Finally, a couple smaller points:
a. Only numerical sender id which can identify the telemarketer is unnecessary since (a) it takes away from use of sender id as a key marketing tool and (b) the current sender id helps a consumer identify that it is a commercial/promotional SMS and it is easy to trace the sender.
b. A massive number of messages possible when a mobile number opts in to one of the seven categories. This proposal seems self-defeating, and will probably not end up being used. As a result, the list will be a binary one – all blocked or all enabled. This is where the concept of explicit opt-in to specific brands and companies needs to be taken into account.
The issues highlighted here need immediate action, else the danger is that come Jan 1, 2011 both consumers and telemarketers will be left unhappy – which was definitely not the intent of TRAI in drafting the regulations.